{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.85, "record_type": "conflict", "pair_id": "conflict:b400b8b18c0f47dc84ab932d", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_GDPR"}, "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": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "875a079a95591434::4e2::744f", "source_doc": "PriorTFR_Regulation_EU_2015-847.pdf", "page": 2, "passage": "For example, personal data collected for the purpose of complying\nwith this Regulation should not be further processed in a way that is incompatible with Directive 95/46/EC. In\nparticular, further processing of personal data for commercial purposes should be strictly prohibited. The fight\nagainst money laundering and terrorist financing is recognised as an important public interest ground by all\nMember States. Therefore, in applying this Regulation, the transfer of personal data to a third country which does\nnot ensure an adequate level of protection in accordance with Article 25 of Directive 95/46/EC should be\npermitted in accordance with Article 26 thereof. It is important that payment service providers operating in\nmultiple jurisdictions with branches or subsidiaries located outside the Union should not be prevented from\ntransferring data about suspicious transactions within the same organisation, provided that they apply adequate\nsafeguards. In addition, the payment service providers of the payer and of the payee and the intermediary\npayment service providers should have in place appropriate technical and organisational measures to protect\npersonal data against accidental loss, alteration, or unauthorised disclosure or access."}], "evidence_b": [{"chunk_id": "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": "EU_GDPR (Article 44+ cross-border data transfer restrictions, plus general lawful-basis requirements) and INT_FATF_VASP (FATF VASP standards mandating originator/beneficiary information collection and sharing for VA transfers — travel rule). When an EU CASP/VASP implements the FATF travel rule, it must share personal data with non-EU counterparty VASPs; GDPR Chapter V restrictions engage. Operationally resolvable via GDPR Art. 6(1)(c) (legal obligation under EU TFR) + Chapter V transfer mechanism (SCCs / derogation for important reasons of public interest). Same shape as the labelled EU TFR ↔ EU GDPR conflict in the careful cohort, generalised to the international FATF standard.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:25:42Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:30:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:92078ba635e6e54417e5c897", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "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": "b49627bb889ef1d9::1b6::0802", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 63, "passage": "Dealing with an entity that is not subject to AML/CFT regulation would also similarly\npose higher ML/TF risks. II-3-6 MAS will apply a risk-based approach to supervision of DPT providers. This will\ninclude robust licensing fit and proper checks, and inspections to be conducted to\ntest FIs' effectiveness at combating ML/TF and PF. MAS' AML/CFT supervision\nwill also be supplemented by findings from MAS' surveillance of higher risk areas"}], "rationale": "The evidence from AU_TREASURY_DAP discusses the Australian government's 'token mapping' exercise to identify how crypto assets fit into existing financial services laws and the subsequent development of a licensing framework for crypto asset service providers (chunk_id=d75262e404517e0c::47b::7c9f). The evidence from SG_MAS_AML_GENERAL focuses on the Monetary Authority of Singapore's (MAS) application of a risk-based approach to supervision of Digital Payment Token (DPT) providers, including robust licensing fit and proper checks and inspections to combat money laundering and terrorism financing (chunk_id=b49627bb889ef1d9::1b6::0802). The two regimes address the regulation of crypto assets from different jurisdictions and angles (licensing frameworks vs. AML/CFT supervision), with no specific obligation in one regime pushing against a specific obligation in the other. Therefore, the regimes are in non_conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:af3b9b88a1e5b802d84b5cc5", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "regime_b": {"regime_id": "SG_MAS_PRUDENTIAL_CRYPTO", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_PRUDENTIAL_CRYPTO"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}], "evidence_b": [{"chunk_id": "7c04f2a0bd85290a::449::02f2", "source_doc": "2023_Annex_Stablecoin_Submissions.pdf", "page": 58, "passage": "We also acknowledge that the SCS sector is still relatively nascent and therefore,\nintroducing a risk-based capital framework would entail additional compliance costs. On\nthe other hand, we wish to highlight that their growth is remarkably fast, bringing\nsignificant opportunities, but also challenges to market integrity and consumer protection\nwhich can be mitigated by a robust regulatory framework. The recent developments in the crypto market and the price volatility of crypto assets,\nunderscore the need for a robust regulatory framework, something that MAS has\nhighlighted as well. Hence, given that banks which offer SCS issuance services are subject 15 August 2023 | 61\nto a risk-based capital framework, we believe that non-banks should be subject to the\nsame requirements. Meeting the same risk-based capital requirements would ensure\nmarket stability and it will be in line with the MAS'S intention to impose higher financial\nand prudential standards on SCS issuers compared to other payment service providers, in\nline with the \"same activities, same risk, same regulation\" principle."}], "rationale": "INT_BASEL_GENERAL (Basel III leverage ratio / capital framework) and SG_MAS_PRUDENTIAL_CRYPTO (MAS's risk-based capital framework for SCS issuers, considering Basel principles). MAS explicitly aligns its prudential approach with Basel; the cited B passage acknowledges introducing a risk-based capital framework consistent with Basel-style principles. Reinforcing rather than contradicting."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:19da30de88f9469286cc90a2", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS234", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_CPS234"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "4b6fab404e7acfca::3c4::1564", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": null, "passage": "This licence\nallows you to copy, distribute and adapt this work, provided you attribute the work and do not suggest that\nAPRA endorses you or your work. To view a full copy of the terms of this licence, visit\nhttps://creativecommons.org/licenses/by/3.0/au/\nAPRA June 2024 1 About this guide\nPrudential practice guides (PPGs) share APRA's views on sound practice. They discuss requirements from\nlegislation, regulations or APRA's prudential standards, but do not themselves create enforceable requirements. This PPG offers guidance to APRA-regulated entities to aid compliance with Prudential Standard CPS 230\nOperational Risk Management (CPS 230). CPS 230 sits within the Risk Management pillar of APRA's framework,\nas a supporting standard. Effective operational risk management is essential to ensure the resilience of an entity, and its ability to maintain\ncritical operations through disruptions. Proportionality\nCPS 230 applies to every APRA-regulated entity."}], "evidence_b": [{"chunk_id": "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": "AU_APRA_CPS234 (APRA Information Security prudential standard) and INT_BASEL_GENERAL (Basel III framework — capital adequacy, leverage ratio). Both prudential frameworks but addressing different specific concerns — APRA CPS 234 is information-security and cybersecurity; Basel III is capital adequacy. Different focuses; no direct overlap on the cited passages."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:22:59Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:cd831945b9c47b60aaee9889", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "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": "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": "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_NIS2 passage discusses the preparation of technical standards and guidelines for access controls and ICT security measures (chunk_id 3c9eb3a25c93f394::474::4786). The INT_IOSCO_GENERAL passage outlines the IOSCO Principles and their role in establishing standards for securities regulation and market oversight (chunk_id f173909614befd49::455::1a1a). The obligations in these regimes regulate distinct domains: EU_NIS2 focuses on digital operational resilience and ICT security, while INT_IOSCO_GENERAL focuses on securities market regulation and disclosure. There is no specific obligation in one regime that pushes against a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:9a1e9491250a31d3c4cc29e7", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "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": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLA Regulation establishing the AML supervisor and EU DORA ICT operational-resilience regulation operate in disjoint regulatory domains at the obligation level. EU AML supervisor vs EU ICT-resilience regulation — 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": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:391b88136bdb424c75d1f6ee", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "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."}], "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": "FATF_R16 (FATF Recommendation 16 — VA/VASP AML travel rule) and INT_IOSCO_GENERAL (IOSCO securities regulation objectives and principles). Both are international standards bodies addressing financial regulation from different angles (AML/CFT for VASPs and securities markets / investor protection); FATF and IOSCO publish coordinated guidance on crypto-related issues. Complementary pillars of international financial regulation."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:15:26Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:2c666a8d1a61199eef9e2b64", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "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": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "rationale": "The evidence from Regime A (AU_AML_CTF) outlines obligations for reporting suspicious matters and threshold transactions to AUSTRAC (chunk_id 254ca2d92d196180::2ac::a5fe). The evidence from Regime B (INT_BASEL_CRYPTO) defines bank exposures for capital requirements and discusses risk-weighting methodologies (chunk_id 32afd37cade34f84::3a4::1a5b). The obligations in Regime A relate to financial crime reporting and compliance, while the obligations in Regime B relate to prudential capital adequacy and risk management. The regimes regulate distinct aspects of financial activity and do not impose conflicting obligations on the same conduct."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:9e62057c538f7ac9aab5d517", "label": "conflict", "regime_a": {"regime_id": "AU_ASIC_CRYPTO", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_ASIC_CRYPTO"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "conflict_type": "interpretive_fact_sensitive", "severity": "low", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::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": "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": "EU_REVERSE_SOLICITATION and AU_ASIC_CRYPTO (ASIC's INFO 225 framework — when crypto is a financial product). An AU AFS-licensee serving EU clients depends on whether the interaction qualifies for reverse solicitation — fact-sensitive determination. Low severity because AFSL-only firms generally can't actively solicit EU clients regardless.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:10Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "low", "original_review_status": "single_annotation"}}
{"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:d7a38bd7ce1a5f5867240b9c", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title IV (EMT)"}, "regime_b": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title V (CASP)"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::321::0923", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 74, "passage": "Article 57\nVoluntary classification of e-money tokens as significant e-money tokens\n1.\nAn issuer of an e-money token, authorised as a credit institution or as an electronic money institution, or applying\nfor such authorisation, may indicate that it wishes for its e-money token to be classified as a significant e-money token.\nIn that case, the competent authority shall immediately notify such request of the issuer to EBA, to the ECB and, in the\ncases referred to in Article 56(3), second subparagraph, to the central bank of the Member State concerned.\nIn order for the e-money token to be classified as significant under this Article, the issuer of the e-money token shall\ndemonstrate, through a detailed programme of operations, that it is likely to meet at least three of the criteria set out in"}, {"chunk_id": "491a2f0014d56ffb::53d::70f2", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 13, "passage": "(66)\nIssuers of e-money tokens should be authorised either as a credit institution under Directive 2013/36/EU or as an\nelectronic money institution under Directive 2009/110/EC. E-money tokens should be deemed to be 'electronic\nmoney' as that term is defined in Directive 2009/110/EC and their issuers should, unless specified otherwise in\nthis Regulation, comply with the relevant requirements set out in Directive 2009/110/EC for the taking up,\npursuit and prudential supervision of the business of electronic money institutions and the requirements on\nissuance and redeemability of e-money tokens. Issuers of e-money tokens should draw up a crypto-asset white\npaper and notify it to their competent authority. Exemptions regarding limited networks, regarding certain\ntransactions by providers of electronic communications networks and regarding electronic money institutions\nissuing only a limited maximum amount of electronic money, based on the optional exemptions specified in\nDirective 2009/110/EC, should also apply to e-money tokens. However, issuers of e-money tokens should still be\nrequired to draw up a crypto-asset white paper in order to inform buyers about the characteristics and risks of\nthe e-money tokens and should also be required to notify the crypto-asset white paper to the competent authority\nbefore its publication."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::eb::35e6", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 59\nAuthorisation\n1.\nA person shall not provide crypto-asset services, within the Union, unless that person is:\n(a) a legal person or other undertaking that has been authorised as crypto-asset service provider in accordance with"}, {"chunk_id": "491a2f0014d56ffb::452::8eaf", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 63; or\n(b) a credit institution, central securities depository, investment firm, market operator, electronic money institution,\nUCITS management company, or an alternative investment fund manager that is allowed to provide crypto-asset\nservices pursuant to Article 60. EN\nL 150/114 2. Crypto-asset service providers authorised in accordance with Article 63 shall have a registered office in a Member\nState where they carry out at least part of their crypto-asset services. They shall have their place of effective management\nin the Union and at least one of the directors shall be resident in the Union.\n3. For the purposes of paragraph 1, point (a), other undertakings that are not legal persons shall only provide crypto-\nasset services if their legal form ensures a level of protection for third parties' interests equivalent to that afforded by\nlegal persons and if they are subject to equivalent prudential supervision appropriate to their legal form.\n4. Crypto-asset service providers authorised in accordance with Article 63 shall at all times meet the conditions for\ntheir authorisation.\n5."}], "rationale": "Both regimes are parts of the same EU Regulation (MiCA). Title IV regulates issuers of e-money tokens; Title V regulates crypto-asset service providers. They apply to different roles in the crypto-asset value chain — an EMT issuer may also be a CASP, in which case it must comply with both Titles, but the obligations are layered rather than colliding. Title V Article 60 explicitly contemplates EMIs (which Title IV authorises as EMT issuers) acting as CASPs under their existing prudential authorisation. Within-regulation hard negative.", "would_conflict_if": ["MiCA Level-2 RTS imposed a Title-IV-specific obligation that contradicted a Title-V-specific obligation — Level-2 work is coordinated to avoid this."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:31:27Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:a134ddb62cc265e2bb34b3e6", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "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": "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": "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 EU_NIS2 passage discusses the preparation of technical standards and guidelines for access controls and ICT security within the European Union (chunk 3c9eb3a25c93f394::474::4786). The SG_FOUNDATIONAL_LEGISLATION passage discusses the Monetary Authority of Singapore's (MAS) enforcement actions against Initial Coin Offerings (ICOs) and digital token exchanges, as well as its intention to align with FATF standards (chunk b49627bb889ef1d9::3ef::7168). The obligations and regulatory domains are distinct: one pertains to EU-wide ICT security standards, while the other pertains to Singaporean securities and virtual asset regulation. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:12:18Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:1523b0aa6f509e05ac98c9ec", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3c8::f259", "source_doc": "d424.pdf", "page": 39, "passage": "67 See Annex 10 of Basel II (June 2006) for an overview of methodologies for the capital treatment of transactions secured by\nfinancial collateral under the standardised and IRB approaches.\n\n68 Alternatively, banks with appropriate supervisory approval may instead use the Internal Model Method to determine the\nexposure amount, taking into account collateral.\nBasel III: Finalising post-crisis reforms 35\n\n(ii) On-balance sheet netting\n\n135. Where banks have legally enforceable netting arrangements for loans and deposits that meet the\nconditions in paragraph 190 they may calculate capital requirements on the basis of net credit exposures\nas set out in that paragraph.\n(iii) Guarantees and credit derivatives\n\n136. Where guarantees or credit derivatives fulfil the minimum operational conditions set out in\nparagraphs 191 to 193, banks may take account of the credit protection offered by such credit risk\nmitigation techniques in calculating capital requirements."}, {"chunk_id": "32afd37cade34f84::168::f255", "source_doc": "d424.pdf", "page": 7, "passage": "4 Standards on capital requirements for banks' equity investments in funds are available at www.bis.org/publ/bcbs266.pdf; and\nfor capital requirements for bank exposures to central counterparties are set out in Section XI of the counterparty credit risk\nstandards.\nBasel III: Finalising post-crisis reforms 3\n\nA. Individual exposures\nDue diligence requirements"}, {"chunk_id": "cbb1d8ea33595d81::485::a2a2", "source_doc": "bcbs189.pdf", "page": 5, "passage": "Several of the capital requirements introduced by the Committee to mitigate the\nrisks arising from firm-level exposures among global financial institutions will also help to\naddress systemic risk and interconnectedness. These include:\nBasel III: A global regulatory framework for more resilient banks and banking systems 7  capital incentives for banks to use central counterparties for over-the-counter\nderivatives;\n higher capital requirements for trading and derivative activities, as well as complex\nsecuritisations and off-balance sheet exposures (eg structured investment vehicles);\n higher capital requirements for inter-financial sector exposures; and\n the introduction of liquidity requirements that penalise excessive reliance on short\nterm, interbank funding to support longer dated assets. B. Introducing a global liquidity standard\n34. Strong capital requirements are a necessary condition for banking sector stability\nbut by themselves are not sufficient. A strong liquidity base reinforced through robust\nsupervisory standards is of equal importance. To date, however, there have been no\ninternationally harmonised standards in this area."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "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"}, {"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."}, {"chunk_id": "0e996ae99839f19e::43c::be39", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "(2) An organisation, on or before collecting personal data about an\nindividual from another organisation without the individual's\nconsent, must provide the other organisation with sufficient\ninformation regarding the purpose of the collection to allow that\nother organisation to determine whether the disclosure would be in\naccordance with this Act. (3) Subsection (1) does not apply if -\n(a) the individual is deemed to have consented to the\ncollection, use or disclosure (as the case may be) under\nsection 15 or 15A; or\n(b) the organisation collects, uses or discloses the personal\ndata without the individual's consent in accordance with\nsection 17.\n[40/2020]\n(4) Despite subsection (3), an organisation must comply with\nsubsection (5) on or before collecting, using or disclosing personal\ndata about an individual for the purpose of or in relation to the\norganisation -\n(a) entering into an employment relationship with the\nindividual or appointing the individual to any office; or\n(b) managingorterminatingtheemploymentrelationshipwith\nor appointment of the individual.\n[40/2020]"}], "rationale": "The passages for INT_BASEL_CRYPTO focus exclusively on banking capital requirements, risk-weighting exposures, and liquidity standards for financial institutions. The passages for SG_PDPA focus exclusively on the collection, use, and disclosure of personal data, including consent requirements and accountability. The obligations in Regime A relate to financial risk management and prudential supervision, while the obligations in Regime B relate to data protection and privacy. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B; they regulate distinct domains of activity."}
{"annotator_id": 10116, "annotated_at": "2026-06-18T11:48:14Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:20f0b2a5a962e005a09d6643", "label": "conflict", "regime_a": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "conflict_type": "recurring_friction", "severity": "medium", "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."}, {"chunk_id": "d7502c011527b67c::34a::2958", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 32, "passage": "Article 3(1), point (16)(h), of that Regulation;\n___________\n(*) Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in\ncrypto-assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives\n2013/36/EU and (EU) 2019/1937 (OJ L 150, 9.6.2023, p. 40).';\nEN\nL 150/32 (d) the following point is added:\n'(20) \"self-hosted address\" means a self-hosted address as defined in Article 3, point (20), of Regulation (EU)\n2023/1113 of the European Parliament and of the Council (*).\n___________\n(*) Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information\naccompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849 (OJ L 150,\n9.6.2023, p. 1).';\n(3) in Article 18, the following paragraphs are added:\n'5."}, {"chunk_id": "d7502c011527b67c::3e7::ae26", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 13, "passage": "This Regulation shall not apply to a transfer of funds where any of the following conditions is met:\n(a) it involves the payer withdrawing cash from the payer's own payment account;\n(b) it constitutes a transfer of funds to a public authority as payment for taxes, fines or other levies within a Member\nState;\n(c) both the payer and the payee are payment service providers acting on their own behalf;\n(d) it is carried out through cheque images exchanges, including truncated cheques. This Regulation shall not apply to a transfer of crypto-assets where any of the following conditions is met:\n(a) both the originator and the beneficiary are crypto-asset service providers acting on their own behalf;\n(b) the transfer constitutes a person-to-person transfer of crypto-assets carried out without the involvement of a crypto-\nasset service provider. Electronic money tokens, as defined in Article 3(1), point (7), of Regulation (EU) 2023/1114, shall be treated as crypto-\nassets under this Regulation."}, {"chunk_id": "d7502c011527b67c::350::d21f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 14, "passage": ") 2023/1114, where performing one or more crypto-asset services as defined in Article 3(1),\npoint (16), of that Regulation;\n(16) 'intermediary crypto-asset service provider' means a crypto-asset service provider that is not the crypto-asset service\nprovider of the originator or of the beneficiary and that receives and transmits a transfer of crypto-assets on behalf\nof the crypto-asset service provider of the originator or of the beneficiary, or of another intermediary crypto-asset\nservice provider;\n(17) 'crypto-asset automated teller machines' or 'crypto-ATMs' means physical or on-line electronic terminals that enable\na crypto-asset service provider to perform, in particular, the activity of transfer services for crypto-assets, as referred\nto in Article 3(1), point (16)(j), of Regulation (EU) 2023/1114;\n(18) 'distributed ledger address'"}], "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": "EU_AMLR_TFR (EU's Transfer of Funds Regulation 2023/1113 — per-transaction information-accompanying-transfers obligations on crypto-asset service providers) and INT_BASEL_GENERAL (Basel III prudential framework — capital adequacy, leverage ratio, and operational-risk capital requirements on banks). For bank-operated CASPs (large European banks providing crypto-asset services), every transfer of crypto-assets triggers BOTH the TFR personal-data sharing obligation AND a Basel-framework capital consideration (operational risk capital, customer due diligence supporting AML expectations). The friction is recurring: every transaction generates parallel obligations that scale with throughput. Severity medium because both regimes are designed to coexist but the ongoing operational cost is real.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:28:09Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.8, "record_type": "conflict", "pair_id": "conflict:b73bb7391c278bda95302ae8", "label": "conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU Privacy Act + APPs"}, "regime_b": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU Travel Rule (IFTI / EFTI)"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::634::e686", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Disclosing personal information to an overseas\nrecipient where a permitted general situation\nexists\n8.37 The cross-border principle will not apply if a permitted general situation exists for that\ndisclosure (APP 8.2(d)). Section 16A lists five permitted general situations that may exist for a\ncross border disclosure. These situations are set out below, and are discussed in more detail\nin Chapter C (Permitted general situations) (including the meaning of relevant terms).\n16 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 84. Office of the Australian Information Commissioner - APP Guidelines Page 11 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nLessening or preventing a serious threat to life, health or\nsafety\n8.38 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• it is unreasonable or impracticable to obtain the individual's consent to the disclosure,\nand\n• the entity reasonably believes the disclosure is necessary to lessen or prevent a serious\nthreat to the life, health or safety of any individual, or to public health or safety (s 16A(1),\nItem 1)\n8.39 For example, this permitted general situation might apply where an APP entity discloses the\npersonal information of an individual to a foreign authority, based on a reasonable belief\nthat this disclosure will lessen a serious threat to the health or safety of that individual's\nchildren, but seeking the individual's consent may increase the threat."}, {"chunk_id": "e9f6b0a9e797777d::4ba::1af3", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\n15 Explanatory Memorandum, Privacy Amendment (Enhancing Privacy Protection) Bill 2012, p 83. Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nDisclosing personal information to an overseas\nrecipient with the individual's consent after the\nindividual is expressly informed\n8.27 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))\nExpressly inform\n8.28 An APP entity should provide the individual with a clear written or oral statement explaining\nthe potential consequences of providing consent."}, {"chunk_id": "f9ea5fb6d86aeb75::6f0::32e8", "source_doc": "APP_Guidelines_Consolidated.pdf", "page": 4, "passage": "Office of the Australian Information Commissioner - APP Guidelines Page 9 Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.3, October 2025\n8.27 The mechanism may be a single mechanism or a combination of mechanisms. It may be\nestablished by the law or binding scheme that contains the privacy or data protections, or by\nanother law or binding scheme. Alternatively, the mechanism may take effect through the\noperation of cross-border enforcement arrangements between the OAIC and an appropriate\nregulatory authority in the foreign jurisdiction.15\nException 2 - Disclosing personal information\nto an overseas recipient where the country or a\nbinding scheme is prescribed by regulations\n8.28 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where the overseas recipient of the relevant personal information is:\n• subject to the laws of a country prescribed by regulations, or a participant in a binding\nscheme prescribed by regulations,16 and\n• if the country or binding scheme is prescribed subject to conditions, those conditions are\nsatisfied.17\n8.29 Laws and binding schemes are discussed above at paragraphs 8.22-8.23.\n8.30 The Governor-General may make regulations under the Privacy Act to prescribe these\nmatters.18\nException 3 - Disclosing personal information\nto an overseas recipient with the individual's\nconsent after the individual is expressly\ninformed\n8.31 An APP entity may disclose personal information to an overseas recipient without complying\nwith APP 8.1 where:\n• the APP entity expressly informs the individual that if they consent to the disclosure, this\nprinciple will not apply, and\n• the individual then consents to the disclosure (APP 8.2(b))."}], "evidence_b": [{"chunk_id": "561fc09c315f8349::45d::68bb", "source_doc": "Money transferred to and from overseas International funds transfer instruction (IFTI) reports.pdf", "page": null, "passage": "In\nan IFTI-E: e the transfer instruction is carried out or passed on electronically https://www.austrac.gov.au/business/core-guidance/reporting/money-transferred-and-overseas-international-funds-transfer-instruction-ifti-reports 2/6 25/06/2025, 23:15 Money transferred to and from overseas: International funds transfer instruction (IFTI) reports | AUSTRAC e the transfer is within the same financial institution or between financial\ninstitutions, such as banks, building societies or credit unions. An IFTI-E can be either:\ne outgoing - the ordering institution accepts the instruction in Australia and transfers money to the payee via a beneficiary institution overseas e incoming - the ordering institution accepts the instruction overseas and\ntransfers money via a beneficiary institution in Australia. Information required in IFTI-E reports\nIFTI-E reports must include details about everyone involved in the transfer:\ne the payer - the business, organisation or individual who instructs the ordering\ninstitution to transfer money\ne the ordering institution - the institution that accepts the transfer instruction"}, {"chunk_id": "561fc09c315f8349::40f::9c63", "source_doc": "Money transferred to and from overseas International funds transfer instruction (IFTI) reports.pdf", "page": 4, "passage": "chapter 16 of the AML/CTF Rules. IFTI under a designated remittance arrangement (IFTI-DRA) NN An IFTI-DRA is an instruction to transfer money or property to or from another\ncountry under a designated remittance arrangement (DRA) where either:\ne the entity accepting the instruction from the customer or e the entity making the money or property available is not a financial institution. Information required in IFTI-DRA reports Reports about IFTI-DRAs must include details about everyone involved in the\ntransfer: e the transferor - the business, organisation or individual who instructs the\ntransfer of the money or property e the sender - the business, organisation or individual that accepts instructions\nfrom the transferor to transmit the money or property e the transmitter (if the transmitter is not the sender) - the business,\norganisation or individual that transmits the instructions e the disbursing entity - the business, organisation or individual that arranges\nfor the money or property to be made available to the transferee"}, {"chunk_id": "30a32a386d15ba2b::445::e033", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 107, "passage": "International funds transfer An international funds transfer instruction (IFTI) involves either:\ninstruction (IFTI) • an instruction that is accepted in Australia for money or property to be made available\nin another country, or\n• an instruction that is accepted in another country for money or property to be made\navailable in Australia. Legal entity structures Include corporations and trusts that may be set up in simple or highly-complex structures. Layering The second stage of the money laundering cycle, which involves moving, dispersing or\ndisguising illegal funds or assets to conceal their true origin\nLuxury goods Precious stones, jewellery, fashion designer goods, watches, luxury vehicles and watercraft,\ndomestic real estate, artworks and other collectible, and assets and asset classes that are\nused for investment purposes including shares in publically listed companies and other\ninvestment products. Middle East Bahrain, Cyprus, Egypt, Iran, Iraq, Israel, Jordan, Kuwait, Lebanon, Oman, Palestinian\nterritories, Qatar, Saudi Arabia, Syria, Turkey, United Arab Emirates, Yemen"}], "rationale": "AUSTRAC IFTI / EFTI reporting (AML/CTF Act Part 3 Division 4; AML/CTF Rules Chapter 16) requires Australian financial-services and remittance providers to report international funds transfer instructions to AUSTRAC, and in defined cases to disclose originator/beneficiary information to overseas counterpart institutions. APP 8 restricts cross-border disclosure of personal information and (under APP 8.1) makes the disclosing APP entity accountable for the recipient's acts and practices. The tension is concrete — an Australian reporting entity must transmit identifying personal information cross-border to implement the travel rule. Resolution is operational: APP 6.2(b) 'required or authorised by an Australian law' permits the use and onward disclosure under the AML/CTF Act, and APP 8.2(d) (a permitted general situation under s 16A) covers many overseas disclosures to a foreign regulator or FIU. The cost is real but manageable: the reporting entity must document the legal-basis chain in its privacy policy and case-by-case for each overseas counterparty.", "compliant_paths": ["Rely on APP 6.2(b) (required or authorised by law) for the AML/CTF disclosure leg.", "For overseas disclosure to a non-FIU counterparty, layer APP 8.2(d) (s 16A permitted general situation) or APP 8.2(a) (reasonable belief that the recipient is bound by comparable law)."], "out_of_scope_assumptions": ["Reporting entity is registered under the AML/CTF Act."]}
{"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:da879c5ff7b07733dcf078fd", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "regime_b": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EMD2"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "3a1785f95cb37b3c::336::8d0b", "source_doc": "AMLA_Regulation_EU_2024-1620.pdf", "page": 32, "passage": "The list of\nthe selected obliged entities shall be published by the Authority without undue delay upon completion of the selection\nprocess. The Authority shall commence direct supervision of the selected obliged entities six months after publication of\nthe list.\n5. Prior to the publication of the list of the selected obliged entities, the Authority shall inform the relevant\nnon-AML/CFT authorities of the outcomes of the process of assessment and classification of inherent and residual risk of\nthe obliged entities subject to assessment.\n6. A selected obliged entity shall remain subject to direct supervision by the Authority until the Authority commences\nthe direct supervision of selected obliged entities based on a list established for the subsequent selection period which no\nlonger includes that obliged entity."}], "evidence_b": [{"chunk_id": "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 AMLA Regulation establishing the AML supervisor and EU EMD2 e-money-institution directive operate in disjoint regulatory domains at the obligation level. AML supervisory authority vs e-money institution authorisation — disjoint frames. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:01:51Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:7083447ef8f358ce7ab1c7e2", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "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": "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 DAC8 regime focuses on tax transparency and the automatic exchange of information regarding crypto-asset users (c0300673081f7232::320::7b46, c0300673081f7232::498::163c). The FATF R16 regime focuses on Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) standards, specifically regarding digital identity and virtual assets (5d489619a0fb9ecf::377::a91e, 85240528438654b9::396::417b). The obligations in DAC8 (reporting to tax authorities) are complementary to, rather than in conflict with, the obligations in FATF R16 (identifying customers and mitigating AML/CFT risks). The DAC8 text explicitly references the OECD Crypto-Asset Reporting Framework to ensure consistency with international standards (c0300673081f7232::498::163c), which are aligned with FATF recommendations. Therefore, the regimes are in different domains (tax transparency vs. AML/CFT compliance) and do not create a conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:54:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:61e2edfd1d855737948200d5", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::34a::74e3", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 11, "passage": "33. Article 109(1)(d) MiCA requires ESMA to establish a register of CASPs which must be\npublicly available on its website and be updated on a regular basis. Article 109(5) MiCA\nspecifies the information which the register must contain, including the name, legal form\nand legal entity identifier of the CASP and, where applicable, of the where applicable, of\nthe CASP's branches and the list of crypto-asset services provided by the CASP. To\nensure that an application for authorisation also contains all information required for the\nfuture ESMA public register of CASPs, ESMA proposes to include a few additional\ninformation requirements of limited extent to reflect the requirements of Article 109(5) of\nMiCA in the draft RTS on the application for authorisation as a CASP.\n\n4 Complaints-handling procedures of crypto-asset service\nproviders"}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The EU MiCA passages (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::34a::74e3) regulate the licensing and registration of Crypto-Asset Service Providers (CASPs) within the EU. The INT IOSCO passages (f173909614befd49::455::1a1a) provide a general methodology and objectives for securities regulation, referencing the 'Objectives and Principles of Securities Regulation' and cooperation between securities authorities. The obligations in MiCA regarding CASP authorisation and public registers do not overlap with the general principles of securities regulation outlined in the IOSCO methodology. Therefore, the regimes regulate different domains and do not conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:35:46Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:cfed273a21e2aed7c1c77c1e", "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_IRAS_TAX", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_IRAS_TAX"}, "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": "abc2247bc6415d1d::41e::b184", "source_doc": "GST_Digital_Payment_Tokens.pdf", "page": 5, "passage": "Similarly, IRAS has reviewed its GST position to keep up to\ndate with these developments. In particular, IRAS recognises that taxing\ncryptocurrencies that function or are intended to function as medium of\nexchange (that is, digital payment tokens) results in two tax points - once\non the purchase of the cryptocurrency and again on its use as payment for\nother goods and services subject to GST. To better reflect the characteristics\nof digital payment tokens, with effect from 1 Jan 2020, the supply of such\ntokens will no longer be subject to GST. The change in GST treatment does\nnot represent IRAS' endorsement of cryptocurrency investments.\n4.3 With the change, businesses that trade in digital payment tokens are no\nlonger liable for GST registration even if the annual turnover from the trade\nexceeds $1million, as the supplies of the tokens are exempt supplies. However, GST-registered businesses that make both taxable supplies and\nexempt supplies of digital payment tokens will become partially exempt and\nmay have to apportion their input tax."}], "rationale": "The EU regime regulates the solicitation of clients by third-country crypto-asset firms (reverse solicitation exemption), while the Singapore regime addresses the Goods and Services Tax (GST) treatment of digital payment tokens. The EU passages discuss client acquisition and marketing exemptions, whereas the Singapore passages discuss the exemption of digital payment token supplies from GST and the resulting tax registration requirements. The obligations and subject matter are distinct, with no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:03:06Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:1af5bedab274ded1ce2b2622", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "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": "a0d157539d5c8040::2fc::beb4", "source_doc": "FinalReport_Market_Abuse_Guidelines_MiCA.pdf", "page": 6, "passage": "2 Background and Legal Basis\nArticle 92 (3) of MiCA:\nIn order to ensure consistency of supervisory practices under this Article, ESMA shall by 30\nJune 2025 issue guidelines in accordance with Article 16 of Regulation (EU) No 1095/2010 on\nsupervisory practices among the competent authorities to prevent and detect market abuse, if\nnot already covered by the regulatory technical standards referred to in paragraph 2.\n\n1. To promote confidence in markets in crypto-assets and ensure their integrity, Title VI of\nMiCA lays down rules on prevention and prohibition of market abuse involving crypto\nassets.\n\n2. Article 92(1) of MiCA requires any PPAET in crypto-assets to have in place effective\narrangements, systems and procedures to prevent and detect market abuse."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The EU_MICA passages describe specific obligations for crypto-asset service providers, including market abuse prevention (a0d157539d5c8040::2fc::beb4) and the provision of crypto-asset services (f9082873c5d9ba9d::302::bbe0). In contrast, the INT_IOSCO_GENERAL passages discuss general methodology, objectives, and principles for securities regulation, including the 'Objectives and Principles of Securities Regulation' and general disclosure requirements (f173909614befd49::455::1a1a). The regimes regulate different domains: EU_MICA focuses on crypto-assets and MiCA-specific licensing, while INT_IOSCO_GENERAL provides high-level international standards for securities regulation. There is no specific obligation in EU_MICA that pushes against a specific obligation in INT_IOSCO_GENERAL."}
{"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:6078cdad3948840445593c86", "label": "conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "EU_REVERSE_SOLICITATION", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_REVERSE_SOLICITATION"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "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": "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": "EU_REVERSE_SOLICITATION (EU MiCA reverse-solicitation exemption) and AU_TREASURY_DAP (AU DAP licensing framework). Whether an AU DAP-licensed entity can serve EU clients without MiCA authorisation depends on facts about marketing, solicitation, and the specific products offered — not resolvable from the rules alone.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:07Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:33:11Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:072556eb2d415e1d0e1f7ed2", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "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": "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_AML_CTF regime outlines specific reporting obligations for suspicious matters and threshold transactions (chunk 254ca2d92d196180::2ac::a5fe). The MAS_TRM regime, conversely, focuses on the application of principles-based guidelines and risk assessments to licensees (chunk 20d526d712753652::401::f956). The obligations in the AU regime are specific reporting mandates, while the obligations in the MAS regime are high-level principles and best practices. There is no specific obligation in the MAS regime that conflicts with or negates the specific reporting obligations in the AU regime. Therefore, the regimes are in different domains."}
{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.6, "record_type": "non_conflict", "pair_id": "non_conflict:099b1dbc9012ae74dc261d68", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::eb::35e6", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 75, "passage": "Article 59\nAuthorisation\n1.\nA person shall not provide crypto-asset services, within the Union, unless that person is:\n(a) a legal person or other undertaking that has been authorised as crypto-asset service provider in accordance with"}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLD 6 AML supervisory directive and EU MiCA crypto-asset market regulation are designed to coexist — obligations apply cumulatively without collision. MiCA CASPs are AMLR/AMLD6 obliged entities — AML supervisory directive applies cumulatively with MiCA conduct rules. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:51:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:ce3217424124ba7ab2204a92", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "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": "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_AML_CTF passages describe obligations to report suspicious matters and threshold transactions to AUSTRAC (chunk 254ca2d92d196180::2ac::a5fe). The EU_MICA passages describe a legal framework for the provision of crypto-asset services, including advice on crypto-assets (chunk f9082873c5d9ba9d::302::bbe0). The obligations in the AU regime relate to financial crime reporting, while the obligations in the EU regime relate to the licensing and supervision of crypto-asset service providers. The passages do not describe conflicting obligations; rather, they regulate distinct aspects of financial services compliance within their respective jurisdictions."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:27fea5247600525980b437bd", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "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": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "INT_BASEL_GENERAL (Basel III banking prudential framework) and INT_IOSCO_GENERAL (IOSCO securities-regulation principles). Both are international standard-setters working on coordinated global financial regulation; they publish joint reports and are structurally complementary pillars rather than competing regimes. The cited passages confirm they cover distinct but coordinated concerns (bank capital and accounting vs securities regulation principles)."}
{"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:a41087de75864bb9636ea6e3", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLD6", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLD 6"}, "regime_b": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DAC 8 (crypto tax)"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "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": "c0300673081f7232::4d9::6684", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 25, "passage": "B. Due diligence procedures for Entity Crypto-Asset Users\nThe following procedures apply for the purpose of determining whether the Entity Crypto-Asset User is a Reportable\nUser or an Entity, other than an Excluded Person or an Active Entity, with one or more Controlling Persons who are\nReportable Persons.\n1. Determine whether the Entity Crypto-Asset User is a Reportable Person. (a) When establishing the relationship with the Entity Crypto-Asset User, or with respect to Pre-existing Entity\nCrypto-Assets Users by 1 January 2027, the Reporting Crypto-Asset Service Provider shall obtain a self-\ncertification that allows the Reporting Crypto-Asset Service Provider to determine the Entity Crypto-Asset\nUser's residence(s) for tax purposes and confirm the reasonableness of such self-certification based on the\ninformation obtained by the Reporting Crypto-Asset Service Provider, including any documentation collected\npursuant to Customer Due Diligence Procedures. If the Entity Crypto-Asset User certifies that it has no\nresidence for tax purposes, the Reporting Crypto-Asset Service Provider may rely on the place of effective\nmanagement or the address of the principal office to determine the residence of the Entity Crypto-Asset User."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLD 6 AML supervisory directive and EU DAC 8 crypto-asset tax-reporting directive operate in disjoint regulatory domains at the obligation level. AML supervisory directive vs crypto-tax reporting — different regulatory purposes. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:20:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.82, "record_type": "non_conflict", "pair_id": "non_conflict:8dac07524e366570c461fb87", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "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": "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": "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": "EU_PSD2 (Article 97 strong customer authentication for EU payment service providers) and SG_PSA_DPT (MAS PSN02 AML notice for SG DPT licensees). Both regulate payment services broadly but in non-overlapping jurisdictions, and the cited passages address different specific obligations (SCA vs AML/CFT for DPT licensees). No direct obligation tension."}
{"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:8157dd7062a5debc4abb391f", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "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": "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": "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_CORPS_ACT (Australia's Corporations Act 2001 — broad corporate-law framework) and EU_MIFID2 (EU Markets in Financial Instruments Directive — investment-firm conduct of business and product governance). Both regulate financial-services entities and conduct in their respective jurisdictions but with materially different mechanisms — broad AU corporate law vs EU-specific investment-firm directive. Distinct perimeters; no direct conflict on cited passages."}
{"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:0bbc71f301bbd35a89a88f94", "label": "conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU_PRIVACY"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "e9f6b0a9e797777d::5d6::e5ff", "source_doc": "APP_Guidelines_July_2019.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.2, July 2019\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake reasonable steps to ensure that the overseas recipient does not breach the APPs in\nrelation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, of facilitating the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take reasonable steps to ensure that the\nrecipient does not breach the APPs in relation to that information."}, {"chunk_id": "f9ea5fb6d86aeb75::62c::a60c", "source_doc": "APP_Guidelines_Consolidated.pdf", "page": 4, "passage": "Chapter 8: Australian Privacy Principle 8 - Cross-border disclosure of personal information Version 1.3, October 2025\nKey points\n• Before an APP entity discloses personal information to an overseas recipient, the entity must\ntake such steps as are reasonable in the circumstances to ensure that the overseas recipient\ndoes not breach the APPs (other than APP 1) in relation to the information (APP 8.1).\n• An APP entity that discloses personal information to an overseas recipient is accountable for\nany acts or practices of the overseas recipient in relation to the information that would\nbreach the APPs (s 16C).\n• There are exceptions to the requirement in APP 8.1 to take reasonable steps and to the\naccountability provision in s 16C. What does APP 8 say?\n8.1 APP 8 and s 16C create a framework for the cross-border disclosure of personal information. The framework generally requires an APP entity to ensure that an overseas recipient will\nhandle an individual's personal information in accordance with the APPs, and makes the\nAPP entity accountable if the overseas recipient mishandles the information.1 This reflects a\ncentral object of the Privacy Act, to facilitate the free flow of information across national\nborders while ensuring that the privacy of individuals is respected (s 2A(f)).\n8.2 APP 8.1 provides that before an APP entity discloses personal information about an\nindividual to an overseas recipient, the entity must take such steps as are reasonable in the\ncircumstances to ensure that the recipient does not breach the APPs in relation to that\ninformation."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "08b3db1cc7362f25::3bb::5dba", "source_doc": "Guidance-Correspondent-Banking-Services.pdf.coredownload.pdf", "page": null, "passage": "FATF GUIDANCE\nCORRESPONDENT\nBANKING SERVICES\nOCTOBER 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on correspondent banking services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/correspondent-banking-services.html\n© 2016 FATF/OECD."}], "rationale": "AU_PRIVACY (APP 8 cross-border disclosure restrictions) and INT_FATF_GENERAL (FATF general AML/CFT standards including risk-based assessment and cross-border information sharing). FATF standards implemented domestically require sharing of personal data across borders for AML; APP 8 restricts overseas disclosure. Operationally resolvable via APP 6.2(b) (required by law) when AU implements FATF via AML/CTF. Low severity because FATF general is broader than specific obligation; sharpest tension is at the R16/travel-rule level.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:26:01Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:27:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:50ce6a9e263526430eface35", "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_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "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": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}], "rationale": "AU_TTR_THRESHOLD (AUSTRAC threshold-transaction reporting framework — AUD 10,000+ cash transactions) and SG_AML (MAS Notice 314 AML/CFT framework for life insurers). Both jurisdictions implement comparable AML/CFT obligations consistent with FATF standards; entities operating across both face complementary duties."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:05:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:0fe7c98b7eabc0e19a792c1f", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "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": "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": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}], "rationale": "The AU_ATO_CRYPTO passage discusses the Australian tax treatment and adoption of crypto assets (chunk_id e6bb47e92e88e16c::567::36c4). The EU_MIFID2 passage outlines product governance and suitability obligations for investment firms regarding financial instruments (chunk_id 28dfda0f6a6539b6::620::92ed). The obligations relate to distinct regulatory domains: taxation and crypto asset adoption in Australia versus investment services and product governance in the EU. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other. Therefore, the regimes are non-conflicting."}
{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.86, "record_type": "non_conflict", "pair_id": "non_conflict:ad61b324216f1ebbfe35ae94", "label": "non_conflict", "regime_a": {"regime_id": "AU_PRIVACY", "jurisdiction": "Australia", "issuing_body": "OAIC", "short_name": "AU Privacy"}, "regime_b": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU Treasury Digital Asset Platforms"}, "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": "550958b067dc6726::51b::b09b", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 6, "passage": "5 KordaMentha, 'Token mapping: Response to Treasury consultation paper', March 2023. Introduction | 3 laws, digital asset platforms that do not deal in financial products are not subject to financial services\nlaws. The Government intends to introduce a regulatory framework aimed at addressing the significant risks\nand potential harms associated with digital asset platforms, while fostering innovation and safe usage\nof digital assets and distributed ledger technology. The framework outlined in this paper proposes to\nregulate digital asset platforms within the existing Australian financial services laws, while ensuring all\nconsumers and businesses have the opportunity to safely explore and share in any benefits of the\ntechnology. Key terms and concepts used throughout this paper\nUnderstanding the policy problem and the proposed regulatory solution requires an understanding of\nseveral key concepts and terms that are used throughout this paper. These concepts and terms aim to\nreduce the complexity of the paper's content, which necessarily covers topics across industries,\ntechnologies, and regulatory frameworks. They include some broad generalisations for descriptive\nconvenience and some precise technical descriptions for topics stakeholders have identified as causing\nregulatory uncertainty."}, {"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}], "rationale": "The Privacy Act / APPs govern personal information; Treasury's Digital Asset Platforms framework regulates platform-level conduct, custody and tokenisation. The two regimes co-apply to AU digital-asset platforms but address different subject matters. Personal-data handling within a DAP is governed by the Privacy Act; the platform's operational obligations under the DAP framework are independent. Easy hard negative.", "would_conflict_if": ["DAP licensing required public disclosure of customer-level personal data — current framework limits public disclosure to the platform operator and aggregate metrics."]}
{"annotator_id": 10116, "annotated_at": "2026-05-25T23:50:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.65, "record_type": "conflict", "pair_id": "conflict:0aeb0efa378f9da002868d74", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "GDPR"}, "regime_b": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiFID II"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::4a6::7573", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 1, "passage": "Consistent and\nhomogenous application of the rules for the protection of the fundamental rights and freedoms of natural\npersons with regard to the processing of personal data should be ensured throughout the Union. Regarding the\nprocessing of personal data for compliance with a legal obligation, for the performance of a task carried out in\nthe public interest or in the exercise of official authority vested in the controller, Member States should be\nallowed to maintain or introduce national provisions to further specify the application of the rules of this\nRegulation. In conjunction with the general and horizontal law on data protection implementing Directive\n95/46/EC, Member States have several sector-specific laws in areas that need more specific provisions. This\nRegulation also provides a margin of manoeuvre for Member States to specify its rules, including for the\nprocessing of special categories of personal data ('sensitive data'). To that extent, this Regulation does not exclude\nMember State law that sets out the circumstances for specific processing situations, including determining more\nprecisely the conditions under which the processing of personal data is lawful."}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "bd84e63f5b622b73::5e9::a119", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 48, "passage": "Article 25\nData protection by design and by default\n1. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of\nprocessing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the\nprocessing, the controller shall, both at the time of the determination of the means for processing and at the time of the\nprocessing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are\ndesigned to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the\nnecessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of\ndata subjects.\n2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default,\nonly personal data which are necessary for each specific purpose of the processing are processed. That obligation applies\nto the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility.\nIn particular, such measures shall ensure that by default personal data are not made accessible without the individual's\nintervention to an indefinite number of natural persons.\n3. An approved certification mechanism pursuant to Article 42 may be used as an element to demonstrate\ncompliance with the requirements set out in paragraphs 1 and 2 of this Article."}], "evidence_b": [{"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}, {"chunk_id": "28dfda0f6a6539b6::49c::69f4", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 53, "passage": "Member States shall require that investment firms and market operators operating an MTF or an OTF establish,\npublish and maintain and implement transparent and non-discriminatory rules, based on objective criteria, governing\naccess to its facility.\n4. Member States shall require that investment firms and market operators operating an MTF or an OTF have\narrangements to identify clearly and manage the potential adverse consequences for the operation of the MTF or OTF,\nor for the members or participants and users, of any conflict of interest between the interest of the MTF, the OTF, their\nowners or the investment firm or market operator operating the MTF or OTF and the sound functioning of the MTF or\nOTF.\n5. Member States shall require that investment firms and market operators operating an MTF or OTF comply with\nArticles 48 and 49 and have in place all the necessary effective systems, procedures and arrangements to do so.\n6. Member States shall require that investment firms and market operators operating an MTF or an OTF clearly inform\nits members or participants of their respective responsibilities for the settlement of the transactions executed in that\nfacility."}, {"chunk_id": "28dfda0f6a6539b6::50f::a85f", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 68, "passage": "Article 31\nMonitoring of compliance with the rules of the MTF or the OTF and with other legal obligations\n1. Member States shall require that investment firms and market operators operating an MTF or OTF establish and\nmaintain effective arrangements and procedures, relevant to the MTF or OTF, for the regular monitoring of the\ncompliance by its members or participants or users with its rules. Investment firms and market operators operating\nan MTF or an OTF shall monitor the orders sent, including cancellations and the transactions undertaken by their\nmembers or participants or users under their systems, in order to identify infringements of those rules, disorderly\ntrading conditions, conduct that may indicate behaviour that is prohibited under Regulation (EU) No 596/2014 or\nsystem disruptions in relation to a financial instrument and shall deploy the resource necessary to ensure that such\nmonitoring is effective.\n2. Member States shall require investment firms and market operators operating an MTF or an OTF to inform its\ncompetent authority immediately of significant infringements of its rules or disorderly trading conditions or conduct that\nmay indicate behaviour that is prohibited under Regulation (EU) No 596/2014 or system disruptions in relation to a\nfinancial instrument."}], "rationale": "MiFID II Article 25 (suitability and appropriateness assessments) requires investment firms to obtain extensive personal information about retail clients — investment objectives, financial situation, risk tolerance, knowledge and experience. Article 16 organisational requirements add record-keeping (typically five years, or longer at Member-State discretion). Articles 27 (best execution) and 31 (trading-venue surveillance) generate transactional data tied to identifiable clients. GDPR data minimisation and purpose limitation are in tension with the breadth of MiFID II data collection. Resolution is operational: GDPR Art 6(1)(b) (contract performance) covers suitability assessment and order execution; Art 6(1)(c) (legal obligation) covers MiFID-mandated record-keeping; Art 5(1)(e) retention windows tie to MiFID retention periods. Severity low because MiFID II has been operating alongside GDPR since 2018 and the practitioner playbook is mature.", "compliant_paths": ["GDPR Art 6(1)(b) for suitability and order-execution processing.", "GDPR Art 6(1)(c) for MiFID-mandated record-keeping and transaction reporting.", "Tie GDPR Art 5(1)(e) retention windows to MiFID II Art 16 minimum retention."], "out_of_scope_assumptions": ["EU MiFID-authorised investment firm; third-country firms providing services under Article 46/47 have a Chapter V transfer overlay."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:22:09Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:36243ad6dab09dd9ad187b04", "label": "non_conflict", "regime_a": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "d75262e404517e0c::4f1::4905", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Treasury received substantial feedback\nfrom a range of stakeholders with industry-wide support for clarity on the regulatory settings for crypto\nassets. In particular, key stakeholders flagged the need to prioritise the 'token mapping' work, which\ninvolves reviewing a range of crypto assets to identify how they fit within the existing regulatory framework. Accordingly, to commence the reform agenda, I will prioritise the complex 'token mapping' work in 2022. Token mapping is a foundational piece of work to support Government to identify how crypto assets and\nrelated services ought to be regulated. It will also importantly aid the development of a licensing framework\nby assisting in demarcating the perimeter between financial product crypto assets (already the subject of\nfinancial services laws) and non-financial product crypto assets (that may warrant a separate crypto asset\nregulatory framework). Parliament House Canberra ACT 2600 Australia\nOFFICIAL: Sensitive OFFICIAL: Sensitive Subject to your agreement, I propose to announce the reform agenda, commence stakeholder consultations\nand release a public consultation paper on token mapping in 2022 (as indicated in Treasury's earlier\nconsultation paper on crypto licensing and custody requirements)."}, {"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}], "evidence_b": [{"chunk_id": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}, {"chunk_id": "75b61beed88910f9::4ad::debc", "source_doc": "National_ML_TF_Risk_Assessment.pdf.coredownload.inline.pdf", "page": null, "passage": "The guidance contained in this document takes into consideration previous FATF work , which is still valid reference material. The general\nprinciples contained in this paper are also relevant when conducting risk assessments of a more\nfocussed scope, such as in assessments of a particular financial or DNFBP sector (for example, the\nsecurities sector) or of thematic issues (for example, the proceeds of corruption related ML). All of\nthese types of assessments (comprehensive, sectoral or thematic) carried out at the national level\nmay also form the basis for determining whether to apply enhanced or specific measures, simplified\nmeasures, or exemptions from AML/CFT requirements. Furthermore, while FATF\nRecommendation 1 does not create specific risk assessment obligations regarding the financing of\nproliferation of weapons of mass destruction, the general principles laid out in this guidance could\nalso be used in conducting a risk assessment for this area.\n3. The guidance in this document is not intended to explain how supervisors should assess risks\nin the context of risk-based supervision, although risk-based supervision will likely be informed by a\nnational-level risk assessment."}], "rationale": "The AU_TREASURY_DAP passages describe a domestic policy agenda focused on 'token mapping' and the development of a licensing framework for crypto assets to fit within existing financial services laws (chunk_ids d75262e404517e0c::4f1::4905, e6bb47e92e88e16c::37a::29f6). In contrast, the INT_FATF_GENERAL passages provide general guidance on anti-money laundering (AML) and counter-terrorist financing (CFT) risk assessment principles and standards (chunk_ids fe52dd87e13dba41::261::59a4, 75b61beed88910f9::4ad::debc). The regimes regulate different domains: one is a domestic regulatory reform initiative for crypto assets, while the other is an international standard-setting body's guidance on financial crime risks. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:57:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:e8774251abd6f8c35253dc6d", "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_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "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": "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 AML/CTF regime regulates reporting entities and their obligations to identify customers and report suspicious transactions (chunk cf7cefacba3f94bc::49a::f39e). The Singapore stablecoin regime regulates the issuance and reserve requirements of Single Currency Stablecoins (SCS) issued in Singapore (chunk 58f45cd2ef3de201::36c::e2f6). The passages describe distinct regulatory domains: one focuses on anti-money laundering compliance for financial service providers, while the other focuses on the issuance standards for specific digital assets. There is no evidence of a specific obligation in the Australian regime conflicting with a specific obligation in the Singapore stablecoin regime."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:09:05Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b42c8dfe5da94cbb14068a84", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "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": "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": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The AU_ASIC_AFSL regime regulates the licensing and conduct of financial services providers in Australia, specifically regarding digital asset facilities (chunk 550958b067dc6726::709::b159). The INT_IOSCO_GENERAL regime provides a methodology for adopting IOSCO principles and standards, which are high-level objectives for securities regulation (chunk f173909614befd49::455::1a1a). The obligations in Regime A are specific operational and licensing requirements for entities operating in Australia, while Regime B outlines general international standards and principles. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B; rather, Regime B provides the overarching framework that Regime A implements. Therefore, the regimes are in different domains and do not conflict."}
{"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:f30206a7bd36eb89e3ae19d4", "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": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "MAS AML/CFT Notices"}, "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": "39886a6842407c92::319::727a", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 31, "passage": "11.8 All wire transfer originator and beneficiary information collected by the ordering institution\nshall be documented.\n\n11.9 Where the ordering institution is unable to comply with the requirements in paragraphs\n11.3 to 11.8, it shall not execute the wire transfer.\nResponsibility of the Beneficiary Institution\n\n11.10 A bank that is a beneficiary institution shall take reasonable measures, including post-\nevent monitoring or real-time monitoring where feasible, to identify cross-border wire\ntransfers that lack the required wire transfer originator or required wire transfer beneficiary\ninformation.\n\n11.11 For cross-border wire transfers, a beneficiary institution shall identify and verify the\nidentity of the wire transfer beneficiary if the identity has not been previously verified."}], "rationale": "CPS 234 regulates information-security capability of APRA-regulated Australian financial entities; MAS AML/CFT Notices regulate AML/CFT operational controls (CDD, wire-transfer travel rule, transaction monitoring) on MAS-regulated Singapore FIs. Different jurisdictions, different domains, different regulated populations. There is no plausible mechanism by which one's obligations contradict the other's. This is a deliberate easy negative for the conflict-detector training set.", "would_conflict_if": ["A single entity were dual-regulated and one regime mandated a control that the other prohibited — there is no such scenario in the cited text."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:19:06Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:6d7bbf3cb1b29dc6aee9e384", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "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": "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": "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_NIS2 passage discusses the preparation of technical standards and guidelines for access controls and ICT security measures (chunk_id 3c9eb3a25c93f394::474::4786). The SG_MAS_AML_GENERAL passage discusses the application of a risk-based approach to supervision of Digital Payment Token (DPT) providers, including robust licensing and inspections to combat money laundering and terrorism financing (chunk_id b49627bb889ef1d9::1b6::0802). The obligations in the EU_NIS2 passage relate to the technical implementation of ICT security (access controls), while the obligations in the SG_MAS_AML_GENERAL passage relate to the regulatory supervision and licensing of entities to prevent financial crime. These are distinct regulatory domains; the ICT security measures required by NIS2 do not conflict with the AML/CFT supervision requirements of MAS."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:01:00Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:54d2d9f2577130008e68b32e", "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_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "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": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}, {"chunk_id": "c51ad46265cea4e5::361::e378", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 16, "passage": "57. ESMA is mandated in Article 84(4) of MiCA to develop, in close cooperation with EBA,\ndraft regulatory technical standards (RTS) on the detailed content of the information for\nthe assessment of proposed acquisitions of qualifying holdings in CASPs. The aim of\nthis draft RTS is to specify the detailed content of the information that direct or indirect\nproposed acquirers must provide to national competent authorities (NCAs) when\nnotifying the intended acquisition. This should ensure a harmonised approach to the\nassessment across Member States in the EU of the intended acquisition of qualifying\nholdings in CASPs.\n\n58. The RTSs are applicable to proposed acquirers of qualifying holdings in CASPs, as well\nas NCAs as designated under Article 93(1) of MiCA that will conduct the assessment of\nthe intended acquisition in accordance with Article 83(4) of MiCA."}], "rationale": "The AU_TRAVEL_RULE passages describe the Australian regulatory framework for remittance networks and virtual asset service providers, including the correction of entries on registers and the definition of 'tracing information' for transfers of value. The EU_MICA_RTS passages describe the European regulatory framework for crypto-asset service providers (CASPs), specifically the notification requirements for entities providing crypto-asset services and the regulatory technical standards (RTS) for assessing proposed acquisitions of qualifying holdings in CASPs. The obligations in the AU regime relate to the registration and correction of entries for remittance and virtual asset providers, while the obligations in the EU regime relate to the notification of crypto-asset services and the assessment of acquisitions of CASPs. These are distinct regulatory domains with no apparent overlap of obligations or conflicting requirements."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:51:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:994fb3a805c9db2e29f95446", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "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": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The EU PSD2 passages regulate the authentication of payment transactions and the authorisation of payment institutions (chunk_ids adb1a81b9cecaf8c::64f::f5ad, adb1a81b9cecaf8c::31a::3b3b). The SG FSMA DTSP passages regulate the licensing of Digital Token Service Providers (DTSPs) and the conduct of digital token services (chunk_ids 20d526d712753652::404::80be, cc1be49e9cf8c821::2f4::ea8f). The obligations in PSD2 regarding strong customer authentication and security credentials do not overlap with the obligations in the SG regime regarding licensing, exemptions, or the conduct of digital token services. Therefore, the regimes are in different domains and do not conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:42:00Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:b25b8b5056fe4aebfb223e59", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "AU_APRA_CPS230"}, "regime_b": {"regime_id": "EU_MICA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA"}, "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": "f9082873c5d9ba9d::302::bbe0", "source_doc": "FinalReport_Knowledge_and_Competence_MiCA.pdf", "page": 17, "passage": "2. MiCA sets out a new legal framework which encompasses requirements for the provision\nof ten different crypto-asset services. These services include the provision advice on\ncrypto-assets; defined in Article 3(1)(24) of MiCA as \"offering, giving or agreeing to give\npersonalised recommendations to a client, either at the client's request or on the initiative\nof the crypto-asset service provider providing the advice, in respect of one or more\ntransactions relating to crypto-assets, or the use of crypto-asset services\". Article\n81(15)(a) of MiCA gives a mandate to ESMA to issue guidelines in accordance with\nArticle 16 of Regulation (EU) No 1095/2010 specifying criteria for the assessment of\nknowledge and competence in accordance with paragraph 7 of this Article."}, {"chunk_id": "c51ad46265cea4e5::462::80d8", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 76, "passage": "6.5 Annex V - Draft RTS pursuant to Article 62(5) of MiCA\nCOMMISSION DELEGATED REGULATION (EU) .../...\nof XXX\nsupplementing Regulation (EU) 2023/1114 of the European Parliament and of the\nCouncil with regard to regulatory technical standards specifying the information to be\nincluded in an application for authorisation as crypto-asset service provider\n(Text with EEA relevance)\nTHE EUROPEAN COMMISSION,\nHaving regard to the Treaty on the Functioning of the European Union,\nHaving regard to Regulation (EU) 2023/1114 of the European Parliament and of the Council\nof 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2012\nand (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/193718, and in particular\nArticle 62(5), third subparagraph, thereof,\nWhereas:\n(1) The information to be provided in an application for authorisation as crypto-asset service\nprovider should be sufficiently detailed and comprehensive to enable competent\nauthorities to assess whether an applicant meets the applicable requirements laid down\nin Title V and, where relevant, Title VI of Regulation (EU) 2023/1114."}], "rationale": "The obligations in APRA CPS 230 relate to operational risk management, business continuity, and the resilience of critical operations for APRA-regulated entities (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). The obligations in EU MiCA relate to the provision of crypto-asset services, market abuse prevention, and the authorisation of crypto-asset service providers (chunk_ids f9082873c5d9ba9d::302::bbe0, c51ad46265cea4e5::462::80d8). The regimes regulate distinct domains—prudential operational resilience versus crypto-asset market conduct and authorisation—resulting in no overlap of obligations."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:58:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:abb3ef46125a52d1837c76df", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "EU_MICA_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": "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": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::340::9399", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 21, "passage": "1. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n2. MiCA sets out a new legal framework applicable to legal persons or other undertakings\nintending to provide crypto-asset services, requiring such entities to submit an\napplication for authorisation containing all the information set out in Article 62(2) of MiCA,\nas specified by the RTS on the information for authorisation as a CASP.\n\n3. The next paragraphs present the cost-benefit analysis of the main policy options included\nin this final report on the requirements for the application for authorisation as a CASP\nunder Article 62 of MiCA.\nProblem identification"}], "rationale": "The obligations in Regime A (AU_TTR_THRESHOLD) relate to the reporting of physical currency transactions exceeding A$10,000 to AUSTRAC. The obligations in Regime B (EU_MICA_TITLE_V_CASP) relate to the authorisation requirements for crypto-asset service providers (CASP) under the Markets in Crypto-Assets Regulation (MiCA). The passages confirm that Regime B governs the licensing and supervision of entities providing crypto-asset services, whereas Regime A governs the reporting of cash transactions. There is no specific obligation in MiCA that conflicts with the AUSTRAC reporting obligation; rather, they regulate distinct domains of financial activity. Therefore, the regimes are non-conflicting."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:27:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:b60ffaaa4f9e8d64f9ce080f", "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_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "cf7cefacba3f94bc::383::7d9d", "source_doc": "AUSTRAC Proliferation Financing in Australia-National Risk Assessment.pdf", "page": 34, "passage": "This obligation applies only to the\nexchange of digital currency to fiat currency and the reverse. Australia has not yet implemented FATF's 'Travel Rule' for digital currency exchanges. The Travel Rule\nwould require businesses to identify all parties involved in transactions (for example, exchanges\nbetween digital currencies), custodial wallet providers and transfers made on behalf of customers. These obligations would provide greater visibility of ultimate beneficial ownership of digital currency\nassets, as well as parties to transactions. AUSTRAC provides guidance to digital currency exchange providers on assessing their risk exposure\nand complying with their AML/CTF obligations. Regulation and guidance can help mitigate proliferation\nfinancing risk exposure, to the extent that AML/CTF measures help protect businesses from a range of\ncriminal misuse, including proliferation financing."}, {"chunk_id": "30a32a386d15ba2b::4f3::edc3", "source_doc": "2024 AUSTRAC Money Laundering NRA.pdf", "page": 76, "passage": "As at March 2024, 389 DCE providers were registered with AUSTRAC.54\nDCE providers must comply with AML/CTF obligations, including identifying their customers,\nmaintaining records and reporting transactions including suspicious matters to AUSTRAC. However, the regulatory framework only applies to the exchange of digital currency to fiat\ncurrency, and vice versa. Australia is currently consulting on AML/CTF reforms, including\nthe range of digital currency services that are captured in legislation. In addition, Australia\nis consulting on requirements that would extend FATF's 'Travel Rule' to digital currency\ntransactions. The Travel Rule would require regulated businesses to identify all parties\ninvolved in transactions. Implementing this would provide greater visibility of the ultimate\nbeneficial ownership of digital currency assets, as well as parties to transactions. Risk rating\nDigital currency exchanges are assessed as posing a medium and increasing money laundering\nvulnerability. Key judgements\n• Criminals exploit DCEs for money laundering as an extension of, and in addition to, traditional\nlayering methodologies.\n• DCEs offer speed, global reach, pseudonymity and can facilitate funds flows to and from\nforeign jurisdictions with low visibility."}], "evidence_b": [{"chunk_id": "20d526d712753652::1a4::2e6e", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Notabene commend's the Monetary Authority of Singapore (MAS) for proposing a\ncomprehensive and detailed regulatory approach for Digital Token Service Providers\n(DTSPs) under the Financial Services and Markets Act 2022. Our comments focus on\nthe alignment of these notices and guidelines with international standards,\nparticularly in light of Financial Action Task Force (FATF) Recommendations,\nincluding the Travel Rule."}], "rationale": "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_FSMA_DTSP confirms that the regime is aligned with FATF Recommendations, including the Travel Rule (chunk_id 20d526d712753652::1a4::2e6e). The regimes are not in conflict because one is a proposed future implementation (AU) while the other is an existing regulatory framework (SG) that is already aligned with the international standard. The tension is one of implementation timelines rather than a direct regulatory clash."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:202e42b24b4e58c4d1ce4866", "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_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "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": "df546f2364aaf9e2::25a::6ab3", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 2, "passage": "(4) This Directive is part of a comprehensive package aiming at strengthening the Union's anti-money laundering and\ncountering the financing of terrorism ('AML/CFT') framework. Together, this Directive and Regulations (EU)\n2023/1113 (6), (EU) 2024/1624 (7) and (EU) 2024/1620 (8) of the European Parliament and of the Council will form\nthe legal framework governing the AML/CFT requirements to be met by obliged entities and underpinning the\nUnion's AML/CFT institutional framework, including the establishment of an Authority for anti-money laundering\nand countering the financing of terrorism (AMLA)."}], "rationale": "AU_FEDREG_AML (Australian AML/CTF Act and Rules — AUSTRAC reporting-entity framework) and EU_AMLA (EU Anti-Money Laundering Authority — supervisory cooperation framework under AMLD6). Both implement AML/CFT supervisory architecture in their jurisdictions consistent with FATF standards. Reinforcing."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:29:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:7010cc7a831c5f78cb8b5f5b", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}, {"chunk_id": "32afd37cade34f84::3ec::a3fa", "source_doc": "d424.pdf", "page": 16, "passage": "37. Exposures to securities firms and other financial institutions will be treated as exposures to banks\nprovided that these firms are subject to prudential standards and a level of supervision equivalent to those\napplied to banks (including capital and liquidity requirements). National supervisors should determine\nwhether the regulatory and supervisory framework governing securities firms and other financial\ninstitutions in their own jurisdictions is equivalent to that which is applied to banks in their own\njurisdictions. Where the regulatory and supervisory framework governing securities firms and other\nfinancial institutions is determined to be equivalent to that applied to banks in a jurisdiction, other national\nsupervisors may allow their banks to risk weight such exposures to securities firms and other financial\ninstitutions as exposures to banks. Exposures to all other securities firms and financial institutions will be\ntreated as exposures to corporates.\n\n7. Exposures to corporates"}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}, {"chunk_id": "39886a6842407c92::356::ee53", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 6, "passage": "3.1 This Notice is based on the following principles, which shall serve as a guide for all banks\nin the conduct of their operations and business activities:\n(a) A bank shall exercise due diligence when dealing with customers, natural persons\nappointed to act on the customer's behalf, connected parties of the customer and\nbeneficial owners of the customer.\n(b) A bank shall conduct its business in conformity with high ethical standards, and\nguard against establishing any business relations or undertaking any transaction,\nincluding a digital token transaction, that is or may be connected with, or facilitates\nor may facilitate money laundering or terrorism financing.\n(c) A bank shall, to the fullest extent possible, assist and cooperate with the relevant\nlaw enforcement authorities in Singapore to prevent money laundering and\nterrorism financing."}], "rationale": "The Basel Crypto regime (Regime A) focuses on prudential capital requirements, risk-weighting exposures, and supervisory equivalence for financial institutions (chunk_ids 32afd37cade34f84::3a4::1a5b, 32afd37cade34f84::3ec::a3fa). The Singapore AML regime (Regime B) focuses on customer due diligence, training, and the prevention of money laundering and terrorism financing (chunk_ids 3d521e61e49aaf46::38f::e615, 39886a6842407c92::356::ee53). The obligations in Regime A relate to financial stability and capital adequacy, while the obligations in Regime B relate to compliance and risk management. There is no specific obligation in the Basel Crypto regime that pushes against a specific obligation in the Singapore AML regime; rather, they regulate distinct aspects of banking operations. Therefore, the regimes are in different domains."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:49:33Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:e3c2cef3843b2cab5247a977", "label": "non_conflict", "regime_a": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}, {"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}], "rationale": "The IOSCO passages (chunk f173909614befd49::455::1a1a) discuss general international standards and principles for securities regulation, including disclosure and cooperation. The SG_FSMA_DTSP passages (chunks 20d526d712753652::404::80be and cc1be49e9cf8c821::2f4::ea8f) regulate the licensing and conduct of Digital Token Service Providers (DTSPs) under Singapore's FSM Act. While the SG passages mention alignment with international standards and FATF, they do not impose specific obligations that conflict with the general IOSCO principles. The regimes regulate distinct operational areas (general securities standards vs. specific digital token service provider licensing), resulting in no direct conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:13:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:2104575f2f12274ba839e770", "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_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "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": "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 EU MIFID2 passages regulate the conduct of investment firms, specifically regarding product governance, suitability assessments, and client information disclosure (e.g., Article 1, Article 24, Article 25). The SG_PSA_DPT passages regulate the licensing and AML/CFT compliance of Digital Payment Token (DPT) service providers under the Payment Services Act. While both regimes apply to entities dealing with financial instruments (MIFID2) and digital payment tokens (PSA), the obligations are distinct: MIFID2 focuses on the suitability and best interests of the client, whereas PSA focuses on licensing, surveillance, and anti-money laundering controls. There is no specific obligation in MIFID2 that directly conflicts with the specific obligations in PSA regarding DPT operations. The regimes regulate different aspects of the financial services value chain (conduct of business vs. licensing and AML/CFT)."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:45:05Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:7eb4b43e9e16cbf7a296b899", "label": "non_conflict", "regime_a": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_CORPS_ACT"}, "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": "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": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}], "rationale": "The evidence from 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_id 0fc4f857c226f510::375::66b5). The evidence from the EU MiCA Title V CASP (Regime B) outlines the requirements for authorisation as a Crypto-Asset Service Provider (CASP) under Article 62, specifically mandating that legal persons intending to provide crypto-asset services submit an application to their National Competent Authority (chunk_id c51ad46265cea4e5::147::6214). The obligations in Regime A relate to general corporate governance and winding up, while Regime B addresses the licensing and authorisation of crypto-asset service providers. These are distinct regulatory domains with no apparent overlap of obligations, resulting in a non-conflict classification."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:1a5a7d086d45cf2f2af157c2", "label": "non_conflict", "regime_a": {"regime_id": "AU_APRA_PRUDENTIAL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_APRA_PRUDENTIAL"}, "regime_b": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "f7803fb0f472e356::41a::fb28", "source_doc": "Basel-II-Enhancements-RIS-May-2011.pdf", "page": 4, "passage": "The crisis has shown that collateralised debt obligations comprised of\nasset-backed securities (i.e. CDOs of ABS or so-called 'resecuritisations') are more\nhighly correlated with risk than are traditional securitisations. APRA reviewed its\nprudential standard for securitisation and assessed that the current requirements do not\ncapture the risks associated with these resecuritisation structures. The BCBS also formed the view that increased disclosure requirements should\nprovide timely, relevant, reliable and useful decision-making information that\npromotes institutional transparency. APRA also identified that its prudential\nrequirements for disclosure did not cover certain elements relating to an ADI's\nsecuritisation exposures. Therefore, based on APRA's experience as the prudential supervisor during the crisis\nand analysis of its prudential framework for ADIs, APRA believes that the\ndeficiencies that the Basel II enhancements are seeking to address exist in the\nAustralian prudential framework and present risks that require addressing."}], "evidence_b": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "rationale": "AU_APRA_PRUDENTIAL (APRA's broader prudential framework — including Basel-aligned standards) and INT_BASEL_CRYPTO (Basel d424 prudential treatment of crypto-asset exposures by banks). APRA implements Basel-style prudential standards in Australia; the cited A passage is a Basel II Enhancements RIS document confirming the Basel-implementation relationship. Reinforcing."}
{"annotator_id": 10116, "annotated_at": "2026-05-25T02:30:30Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.78, "record_type": "conflict", "pair_id": "conflict:dbc48281c3404aace3c7d27e", "label": "conflict", "regime_a": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "MAS AML/CFT Notices"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "Personal Data Protection Act"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "39886a6842407c92::319::727a", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 31, "passage": "11.8 All wire transfer originator and beneficiary information collected by the ordering institution\nshall be documented.\n\n11.9 Where the ordering institution is unable to comply with the requirements in paragraphs\n11.3 to 11.8, it shall not execute the wire transfer.\nResponsibility of the Beneficiary Institution\n\n11.10 A bank that is a beneficiary institution shall take reasonable measures, including post-\nevent monitoring or real-time monitoring where feasible, to identify cross-border wire\ntransfers that lack the required wire transfer originator or required wire transfer beneficiary\ninformation.\n\n11.11 For cross-border wire transfers, a beneficiary institution shall identify and verify the\nidentity of the wire transfer beneficiary if the identity has not been previously verified."}, {"chunk_id": "f5d3fd73849ee27c::3b9::4f9f", "source_doc": "MAS_Notice_PSN01_2024-04-02.pdf", "page": 36, "passage": "15.10 All wire transfer originator and beneficiary information collected by the ordering institution\nshall be documented.\n\n15.11 Where the ordering institution is unable to comply with the requirements in paragraphs\n15.3 to 15.10, it shall not execute or arrange for the wire transfer.\n\nResponsibility of the Beneficiary Institution\n\n15.12 A payment service provider that is a beneficiary institution shall take reasonable\nmeasures, including post-event monitoring or real-time monitoring where feasible, to\nidentify cross-border wire transfers that lack the required wire transfer originator or\nrequired wire transfer beneficiary information.\n\n15.13 For cross-border wire transfers where the beneficiary institution pays out funds in cash or\ncash equivalent to the wire transfer beneficiary in Singapore, a beneficiary institution shall\nidentify and verify the identity of the wire transfer beneficiary if the identity has not been\npreviously verified."}, {"chunk_id": "61149885d6ded889::6c9::01d7", "source_doc": "MAS_Notice_824_FinanceCompanies_2025-06-30.pdf", "page": 32, "passage": "11.7 In a domestic wire transfer, every finance company that is an ordering institution shall\neither -\n(a) include in the message or payment instruction that accompanies or relates to the\nwire transfer the following:\n(i) the name of the wire transfer originator;\n(ii) the wire transfer originator's account number (or unique transaction\nreference number where no account number exists); and\n(iii) any of the following\n(A) the wire transfer originator's:\n(1) residential address; or\n(2) registered or business address, and if different, principal place\nof business,\nas may be appropriate;\n(B) the wire transfer originator's unique national identification number\n(such as an identity card number, birth certificate number or passport\nnumber, or where the wire transfer originator is not a natural person,\nthe incorporation number or business registration number);\n(C) the date and place of birth, incorporation or registration of the wire\ntransfer originator (as may be appropriate); or\n(b) include only the wire transfer originator's account number (or unique transaction\nreference number where no account number exists), provided -\n(i) that these details will permit the transaction to be traced back to the wire\ntransfer originator and wire transfer beneficiary;\n(ii) the ordering institution shall provide the wire transfer originator information\nset out in paragraph 11.7(a) within 3 business days of a request for such\ninformation by the beneficiary institution, by the Authority or other relevant\nauthorities in Singapore; and\n(iii) the ordering institution shall provide the wire transfer originator information\nset out in paragraph 11.7(a) immediately upon request for such information\nby law enforcement authorities in Singapore."}], "evidence_b": [{"chunk_id": "0e996ae99839f19e::38f::d3ab", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 32, "passage": "Transfer of personal data outside Singapore\n26.-(1) An organisation must not transfer any personal data to a\ncountry or territory outside Singapore except in accordance with\nrequirements prescribed under this Act to ensure that organisations\nprovideastandardofprotectiontopersonaldatasotransferredthatis\ncomparable to the protection under this Act. (2) The Commission may, on the application of any organisation,\nby written notice exempt the organisation from any requirement 33 Act 2012 2020Ed.\nprescribed pursuant to subsection (1) in respect of any transfer of\npersonal data by that organisation. (3) An exemption under subsection (2) -\n(a) may be granted subject to such conditions as the\nCommission may specify in writing; and\n(b) neednotbepublishedintheGazetteandmayberevokedat\nany time by the Commission. (4) The Commission may at any time add to, vary or revoke any\ncondition imposed under this section."}, {"chunk_id": "0e996ae99839f19e::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::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]"}], "rationale": "MAS AML/CFT Notices 626, 824, 1014 and PSN01 require ordering institutions to collect, transmit and document originator and beneficiary identifying information for wire transfers, and to refuse to execute the transfer where the information cannot be obtained. The PDPA imposes a consent framework on the collection, use and disclosure of personal data, supplemented by Section 26 which forbids transfers of personal data outside Singapore unless comparable protection is ensured. The textual tension is between a consent baseline (PDPA Part 4) plus a cross-border restriction (s 26) on one side, and a mandatory disclosure / transmission obligation (the MAS travel-rule clauses) on the other. The resolution path is operational rather than structural: PDPA Part 4 Division 3 allows collection, use and disclosure without consent where required or authorised under any written law (and the MAS Notices, made under the MAS Act and PSA, are such law); the cross-border restriction is satisfied where the receiving institution is itself subject to comparable AML/CFT obligations. The tension becomes real where the receiving counterparty is in a jurisdiction without comparable protections — there the institution must rely on the prescribed contractual / certification mechanisms or refuse the transfer under the MAS Notices' own paragraphs 11.9 / 15.11.", "compliant_paths": ["Rely on the PDPA 'required or authorised by law' exception for the use/disclosure of originator/beneficiary information under MAS Notices.", "For cross-border transmission, evidence that the receiving institution is bound by comparable obligations (the PDPA s 26 standard) or use a prescribed legally enforceable obligation, e.g. binding contractual clauses.", "When 11.3–11.8 cannot be satisfied, refuse the wire transfer (which is itself the lawful PDPA-compatible outcome)."], "out_of_scope_assumptions": ["The ordering institution is a MAS-regulated FI captured by Notices 626 / 824 / 1014 / PSN01 / PSN02; non-FI obligated entities (e.g. DPT service providers under PSA) follow a parallel but not identical regime.", "Beneficiary institution exists and can be identified — covered-payment-instrument and crypto-asset transfers are not separately analysed here."]}
{"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:fddac77ea19e3358b02d7a03", "label": "conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "AU_TREASURY_DAP", "jurisdiction": "Australia", "issuing_body": "Treasury", "short_name": "AU_TREASURY_DAP"}, "conflict_type": "recurring_friction", "severity": "medium", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::49d::c41e", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 44, "passage": "121 See Corporations Act, s 761E.\nAnnexure 1. Legal and regulatory framework | 41\n\nRegulator: AUSTRAC\nRelevant Legislation: AML/CTF Act\nDigital currency exchanges are regulated by AUSTRAC under the Anti Money Laundering and\nCounter Terrorism Financing (AML/CTF) Act for the purposes of preventing and detecting money\nlaundering and terrorism financing.\nDigital currency exchanges must register with AUSTRAC and meet AML/CTF compliance and\nreporting obligations (including Know Your Customer requirements).\nRegulator: ATO\nRelevant Legislation: Income Tax Act, Goods and Services Tax Act\nInvestors in crypto tokens and other market participants are subject to tax laws. If an entity is\ncarrying on a business in relation to digital currency, or as part of their existing business, or if\nthey are accepting digital currency as a payment in business, the entity needs to consider any\nGST consequences that may arise.\nTax implications for investors flow from the underlying nature of the rights and obligations\nattached to the asset and the personal circumstances of the investor. Crypto tokens will\ngenerally be capital assets, meaning there could be capital gains tax consequences.122"}, {"chunk_id": "d75262e404517e0c::47b::7c9f", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "For example, distributed\ncomputing, document authentication, algorithmic insurance, and micro payments. The ATO estimates that\nmore than one million taxpayers have interacted with the ecosystem since 2018. However, the crypto asset ecosystem presents unique challenges to the existing regulatory framework. In\nparticular, it is difficult to identify the relevant regulatory framework that may, or may not apply to different\ncrypto assets and related services. This causes confusion for various stakeholders including consumers,\nindustry, and regulators. The Select Committee on Australia as a Technology and Financial Centre's Final Report was released in\nOctober 2021 and considered the regulation of the crypto sector. The Final Report found that the sector\nlacked regulatory certainty to ensure safeguards for investors while lending credibility and certainty to the\nindustry. In response, on 21 March 2022, Treasury released a consultation paper on Crypto asset secondary\nservice providers: Licensing and custody requirements seeking views on proposed options for licensing and\ncustody frameworks as well as preliminary views on token mapping."}], "evidence_b": [{"chunk_id": "d75262e404517e0c::4f1::4905", "source_doc": "FOI_3215_Crypto_Asset_Secondary_Service_Providers.pdf", "page": null, "passage": "Treasury received substantial feedback\nfrom a range of stakeholders with industry-wide support for clarity on the regulatory settings for crypto\nassets. In particular, key stakeholders flagged the need to prioritise the 'token mapping' work, which\ninvolves reviewing a range of crypto assets to identify how they fit within the existing regulatory framework. Accordingly, to commence the reform agenda, I will prioritise the complex 'token mapping' work in 2022. Token mapping is a foundational piece of work to support Government to identify how crypto assets and\nrelated services ought to be regulated. It will also importantly aid the development of a licensing framework\nby assisting in demarcating the perimeter between financial product crypto assets (already the subject of\nfinancial services laws) and non-financial product crypto assets (that may warrant a separate crypto asset\nregulatory framework). Parliament House Canberra ACT 2600 Australia\nOFFICIAL: Sensitive OFFICIAL: Sensitive Subject to your agreement, I propose to announce the reform agenda, commence stakeholder consultations\nand release a public consultation paper on token mapping in 2022 (as indicated in Treasury's earlier\nconsultation paper on crypto licensing and custody requirements)."}, {"chunk_id": "e6bb47e92e88e16c::37a::29f6", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": 12, "passage": "16. After token mapping, licensing and custody reforms are the logical next step for crypto reforms\nin Australia. The identification of appropriate obligations and operational standards for crypto\nasset service providers and how they safe-keep assets for customers is a key step for consumer\nprotection; ensuring consumers do not lose assets to avoidable business failure or misuse of\nassets by the provider.\n\n17. The Government will release a consultation paper proposing a licensing and custody framework\nfor crypto asset service providers in mid-2023 to allow for sufficient consultation prior to the\nintroduction of legislation. The paper will reflect ongoing work and consultation in this area and\nleverage the findings from the token mapping exercise. The responses to the following\nquestions will help inform the general direction of future policy and potential consumer\nprotections."}], "rationale": "AU_ATO_CRYPTO (ATO crypto-asset tax framework — every crypto disposal is a CGT event requiring identification of the cost base, recordkeeping, and taxpayer reporting) and AU_TREASURY_DAP (Australia's proposed Digital Asset Platforms licensing regime — operational obligations on platform operators for client services). The friction is recurring: every transaction on a DAP-licensed platform creates a CGT event for the user AND an operational/recordkeeping obligation for the platform. Neither regime creates the other's obligation, but their combination scales with platform throughput, imposing an ongoing cost that is a function of design choice (treating crypto disposals as taxable events rather than as currency transactions).", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:31Z", "decision": "accept", "notes": "", "original_conflict_type": "recurring_friction", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:23:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:c873cf975eddf8676c62e23e", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "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": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}], "rationale": "The evidence from the Australian Taxation Office (ATO) focuses on the taxation of crypto assets and the token mapping process (chunk_id e6bb47e92e88e16c::567::36c4). In contrast, the evidence from the EU MiCA Title IV EMT focuses on the liability of issuers of e-money tokens for information provided in crypto-asset white papers (chunk_id 491a2f0014d56ffb::702::05e4). The obligations described in the EU passage relate to the disclosure and liability standards for issuers, whereas the ATO passage relates to tax compliance and ecosystem mapping. These are distinct regulatory domains with no apparent overlap of obligations."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:24:35Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:7950218a3cbc0a89a7c0190c", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85240528438654b9::396::417b", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 10, "passage": "7. The FATF adopted this Guidance at its June 2019 Plenary. Following the adoption of\nthis Guidance and the revisions to the FATF Standards, the FATF continued its\nenhanced monitoring of the VA sector and the implementation of the revised\nStandards by countries. In March 2020, the FATF released its Guidance on Digital ID\nto assist in identifying customers in the digital context. While this guidance\naddresses Digital ID broadly, it includes useful information for VASPs. In June 2020,\nthe FATF completed its 12-Month Review of the Revised FATF Standards on VAs and\nVASPs, which identified areas where greater FATF guidance was necessary to clarify\nthe application of the revised FATF Standards. Simultaneously with this report, the\nFATF also released its Report to the G20 on So-called Stablecoins. This report sets out\nhow the revised FATF Standards apply to so-called stablecoins and considers the\nAML/CFT issues."}], "evidence_b": [{"chunk_id": "018117ef1e757630::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": "FATF_R16 (FATF Recommendation 16 — international travel-rule standard) and SG_AML (MAS Notice 314 + DPT-specific AML guidance — Singapore's AML/CFT framework). Singapore's AML framework implements FATF standards including R16 for DPT providers. Reinforcing rather than conflicting; SG operates as implementing jurisdiction for the FATF standard."}
{"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:e3e4aa2bee55406d1fc17728", "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_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "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": "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": "EU_MICA_TITLE_V_CASP (EU CASP authorisation requirements under MiCA Article 62) and SG_PSA_GENERAL (Singapore Payment Services Act regulations and amendments). Both regulate crypto/payment service providers but in different jurisdictions; the cited passages address different specific obligations (EU CASP authorisation and ESMA register vs SG PS Regulation amendments on safeguarding). An entity operating across both jurisdictions must comply with each separately."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:37:41Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9a7d1607fa59618eb7558df1", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "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": "28dfda0f6a6539b6::620::92ed", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 8, "passage": "Investment firms that offer or recommend to clients financial instruments not manufactured by them should also\nhave appropriate arrangements in place to obtain and understand the relevant information concerning the product\napproval process, including the identified target market and the characteristics of the product they offer or\nrecommend. That obligation should apply without prejudice to any assessment of appropriateness or suitability\nto be subsequently carried out by the investment firm in the provision of investment services to each client, on the\nbasis of their personal needs, characteristics and objectives. In order to ensure that financial instruments will be offered or recommended only when in the interest of the\nclient, investment firms offering or recommending the product manufactured by firms which are not subject to the\nproduct governance requirements set out in this Directive or manufactured by third-country firms should also have\nappropriate arrangements to obtain sufficient information about the financial instruments. (72) In order to give all relevant information to investors, it is appropriate to require investment firms providing\ninvestment advice to disclose the cost of the advice, to clarify the basis of the advice they provide, in particular the\nrange of products they consider in providing personal recommendations to clients, whether they provide\ninvestment advice on an independent basis and whether they provide the clients with the periodic assessment\nof the suitability of the financial instruments recommended to them."}, {"chunk_id": "28dfda0f6a6539b6::502::1957", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 60, "passage": "Article 25\nAssessment of suitability and appropriateness and reporting to clients\n1. Member States shall require investment firms to ensure and demonstrate to competent authorities on request that\nnatural persons giving investment advice or information about financial instruments, investment services or ancillary\nservices to clients on behalf of the investment firm possess the necessary knowledge and competence to fulfil their\nobligations under Article 24 and this Article. Member States shall publish the criteria to be used for assessing such\nknowledge and competence. 12.6.2014 EN Official Journal of the European Union L 173/409\n2. When providing investment advice or portfolio management the investment firm shall obtain the necessary\ninformation regarding the client's or potential client's knowledge and experience in the investment field relevant to\nthe specific type of product or service, that person's financial situation including his ability to bear losses, and his\ninvestment objectives including his risk tolerance so as to enable the investment firm to recommend to the client or\npotential client the investment services and financial instruments that are suitable for him and, in particular, are in\naccordance with his risk tolerance and ability to bear losses."}], "evidence_b": [{"chunk_id": "20d526d712753652::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_MIFID2 passages regulate the conduct of investment firms, specifically regarding product governance, suitability assessments, and client information disclosure (e.g., Article 1 and Article 25). The SG_MAS_AML_GENERAL passages regulate Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) compliance, including targeted financial sanctions and the supervision of Digital Payment Token (DPT) providers. The obligations in MIFID2 relate to the suitability of financial instruments for clients, whereas the obligations in the MAS passages relate to the prevention of money laundering and terrorism financing. These are distinct regulatory domains; there is no specific obligation in MIFID2 that pushes against a specific obligation in the MAS AML/CFT regime. Therefore, the regimes are non-conflicting."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:30:54Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:e0663db1796334a765d1e73d", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "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": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}], "rationale": "The evidence for the Australian regime (Regime A) focuses on token mapping, tax compliance, and general crypto ecosystem regulation (chunk_id e6bb47e92e88e16c::567::36c4). The evidence for the Singaporean regime (Regime B) focuses on the licensing requirements and operational definitions for Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022 (chunk_id 20d526d712753652::404::80be). The passages describe distinct regulatory frameworks and compliance approaches for the crypto sector in their respective jurisdictions. There is no evidence of a specific obligation in one regime that directly conflicts with a specific obligation in the other; rather, they regulate different domains (tax vs. financial services licensing)."}
{"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:9a67aa400647ab76cac391bd", "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_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU AML/CTF Act + Rules"}, "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": "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 234 information security standard and Australian AML/CTF Act + Rules (binding instruments) operate in disjoint regulatory domains at the obligation level. Info-sec capability vs AML obligations — disjoint, both apply to overlapping regulated population cumulatively. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:59:20Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:e72d3b042dd0a33f2a3deb36", "label": "non_conflict", "regime_a": {"regime_id": "AU_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TTR_THRESHOLD"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "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": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "rationale": "The obligations in Regime A (AU_TTR_THRESHOLD) relate to the reporting of physical cash transactions exceeding A$10,000 to AUSTRAC. The obligations in Regime B (EU_MICA_TITLE_IV_EMT) relate to the liability of issuers of e-money tokens for information provided in crypto-asset white papers and the notification of these white papers to competent authorities. The two regimes regulate distinct transaction types (physical cash vs. e-money tokens) and distinct reporting obligations (AUSTRAC TTRs vs. white paper notifications), with no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:00:06Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:dabb6171bc991dea5ba92093", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "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": "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_AML_CTF regime focuses on reporting obligations for suspicious matters and threshold transactions (chunk 254ca2d92d196180::2ac::a5fe). The SG_STABLECOIN regime outlines a 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 AU regime relate to financial crime reporting, while the SG regime addresses the scope and classification of stablecoin products. There is no specific obligation in the AU regime that conflicts with the specific obligations in the SG regime regarding stablecoin issuance or classification."}
{"annotator_id": 10116, "annotated_at": "2026-05-25T06:30:22Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:c5986c34ae569c1d74c53c52", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "regime_b": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "NIS 2"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}, {"chunk_id": "85307f9e2a040982::7d4::2ed1", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 10, "passage": "(18) Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and\namending Directive 2002/92/EC and Directive 2011/61/EU (OJ L 173, 12.6.2014, p. 349).\n\n27.12.2022 EN Official Journal of the European Union L 333/11\nchanges following post ICT-related incident reviews; to monitor on a continuous basis relevant technological\ndevelopments, to establish a comprehensive digital operational resilience testing programme as an integral part of\nthe ICT risk management framework provided for in this Regulation, or to adopt and regularly review a strategy on\nICT third-party risk. In addition, microenterprises should only be required to assess the need to maintain such\nredundant ICT capacities based on their risk profile. Microenterprises should benefit from a more flexible regime as\nregards digital operational resilience testing programmes. When considering the type and frequency of testing to be\nperformed, they should properly balance the objective of maintaining a high digital operational resilience, the\navailable resources and their overall risk profile. Microenterprises and financial entities subject to the simplified ICT\nrisk management framework under this Regulation should be exempted from the requirement to perform advanced\ntesting of ICT tools, systems and processes based on threat-led penetration testing (TLPT), as only financial entities\nmeeting the criteria set out in this Regulation should be required to carry out such testing. In light of their limited\ncapabilities, microenterprises should be able to agree with the ICT third-party service provider to delegate the\nfinancial entity's rights of access, inspection and audit to an independent third-party, to be appointed by the ICT\nthird-party service provider, provided that the financial entity is able to request, at any time, all relevant information\nand assurance on the ICT third-party service provider's performance from the respective independent third-party."}], "evidence_b": [{"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."}, {"chunk_id": "20d29e9c5300ae10::320::defb", "source_doc": "NIS2_Directive_EU_2022-2555.pdf", "page": 4, "passage": "(15) Entities falling within the scope of this Directive for the purpose of compliance with cybersecurity risk-management\nmeasures and reporting obligations should be classified into two categories, essential entities and important entities,\nreflecting the extent to which they are critical as regards their sector or the type of service they provide, as well as\ntheir size. In that regard, due account should be taken of any relevant sectoral risk assessments or guidance by the\ncompetent authorities, where applicable. The supervisory and enforcement regimes for those two categories of\nentities should be differentiated to ensure a fair balance between risk-based requirements and obligations on the one\nhand, and the administrative burden stemming from the supervision of compliance on the other."}], "rationale": "NIS 2 Recital 24 contains an explicit lex specialis clause: 'Where provisions of a sector-specific Union legal act require essential or important entities to comply with reporting obligations that are at least equivalent in effect to the reporting obligations laid down in this Directive, the consistency and effectiveness of the handling [should be preserved]'. DORA is precisely such a sector-specific Union legal act for EU financial entities, with ICT incident reporting obligations under Articles 17–18. The result is alignment by design: financial entities comply with DORA's regime for ICT-related incidents, NIS 2 applies to non-financial essential / important entities, and the two are coordinated rather than colliding. A labeller might initially see overlap; on close reading, the regulations explicitly carve out their respective scopes.", "would_conflict_if": ["Implementing acts under one regime created a stricter or earlier reporting timer that the other prohibited — Recital 24 is designed to forestall this."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:48:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:18baf6c25e0f9676d71552d0", "label": "non_conflict", "regime_a": {"regime_id": "AU_TRAVEL_RULE", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_TRAVEL_RULE"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_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": "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 AU_TRAVEL_RULE passages discuss the Australian regulatory framework for digital currency exchanges (DCEs), specifically noting that Australia has not yet implemented the FATF 'Travel Rule' for digital currency exchanges and is currently consulting on extending these requirements. In contrast, the SG_PSA_GENERAL passage discusses the definition of 'safeguarding institution' and the licensing of Digital Payment Token Service Providers (DPTSPs) under the Payment Services Act. The two regimes regulate distinct aspects of the digital asset ecosystem—Australia's pending implementation of the Travel Rule versus Singapore's licensing and asset safeguarding framework for DPTSPs. Therefore, the obligations do not conflict."}
{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:6585ef0ca57ebd3265da9a7b", "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_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU TTR Threshold"}, "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": "6dfe4e63b9fb3c74::3bc::1a3f", "source_doc": "Reporting transactions of 10,000 and over Threshold transaction reports (TTRs).pdf", "page": null, "passage": "'@ Australian Government\nAUSTRAC Reporting transactions of\n$10,000 and over:\nThreshold transaction\nreports (TTRs) transaction reports (TTRs) A 'threshold transaction' is the transfer of physical currency (cash) of A$10,000 or more\n(or the foreign currency equivalent) as part of providing a designated service. A transfer\ncan include receiving or paying cash. If you provide a designated service that involves a threshold transaction, you must\nreport these transfers to AUSTRAC in a threshold transaction report (TTR) within 10\nbusiness days. TTRs help us detect, deter and disrupt criminal and terrorist activity. Who must submit TTRs Any business that provides a designated service that involves the transfer of A$10,000\nor more (or the foreign currency equivalent) must submit a TTR to AUSTRAC. If you are an affiliate of a remittance network provider (RNP) and the threshold\ntransaction was made on your RNP's network, they must submit the TTR for you."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): APRA CPS 234 information security standard and AUSTRAC TTR $10k cash threshold reporting operate in disjoint regulatory domains at the obligation level. Info-sec 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": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:cc26a392567deaea5408bde3", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::15a::fbf2", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 80, "passage": "Article 63\nCooperation with AMLA\nFIU and supervisory authorities shall cooperate with AMLA and shall provide it with all the information necessary to allow\nit to carry out its duties under this Directive and under Regulations (EU) 2024/1624 and (EU) 2024/1620.\nSECTION 2\nCooperation with other authorities and exchange of confidential information"}, {"chunk_id": "df546f2364aaf9e2::620::328c", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 79, "passage": "Article 62\nCommunication of the list of the competent authorities\n1. In order to facilitate and promote effective cooperation, and in particular the exchange of information, Member States\nshall communicate to the Commission and AMLA:\n(a) the list of supervisors responsible for overseeing the compliance of the obliged entities with Regulation (EU)\n2024/1624, as well as, where relevant, name of the public authority overseeing self-regulatory bodies in their\nperformance of supervisory functions under this Directive, and their contact details;\n(b) the contact details of their FIU;\n(c) the list of other competent national authorities.\n2. For the purposes of paragraph 1, the following contact details shall be provided:\n(a) a contact point or, failing that, the name and role of a contact person;\n(b) the email and phone number of the contact point or, failing that, the professional email address and phone number of\nthe contact person.\nELI: http://data.europa.eu/eli/dir/2024/1640/oj 79/94\n\nEN\n3. Member States shall ensure that the information provided to the Commission and AMLA pursuant to paragraph 1 is\nupdated as soon as a change takes place.\n4. AMLA shall publish a register of the authorities referred to in paragraph 1 on its website and facilitate the exchange of\ninformation referred to in paragraph 2 between competent authorities. The authorities in the register shall, within the scope\nof their powers, serve as a contact point for the counterpart competent authorities. FIUs and supervisory authorities shall\nalso serve as a contact point for AMLA."}], "evidence_b": [{"chunk_id": "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": "EU_AMLA (EU's new Anti-Money Laundering Authority under Directive 2024/1640 — Article 62-63 cooperation with FIU/supervisory authorities) and FATF_R16 (FATF travel-rule standard). The EU AMLA framework is the EU's institutional implementation arm for AML/CFT, including R16-aligned obligations on CASPs via the TFR. AMLA explicitly cooperates with international AML frameworks. Reinforcing relationship."}
{"annotator_id": 10116, "annotated_at": "2026-06-18T11:48:14Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:79498317229c57c21dbf195a", "label": "conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "AU_CORPS_ACT", "jurisdiction": "Australia", "issuing_body": "ASIC", "short_name": "AU_CORPS_ACT"}, "conflict_type": "operationally_resolvable", "severity": "low", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::462::80d8", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 76, "passage": "6.5 Annex V - Draft RTS pursuant to Article 62(5) of MiCA\nCOMMISSION DELEGATED REGULATION (EU) .../...\nof XXX\nsupplementing Regulation (EU) 2023/1114 of the European Parliament and of the\nCouncil with regard to regulatory technical standards specifying the information to be\nincluded in an application for authorisation as crypto-asset service provider\n(Text with EEA relevance)\nTHE EUROPEAN COMMISSION,\nHaving regard to the Treaty on the Functioning of the European Union,\nHaving regard to Regulation (EU) 2023/1114 of the European Parliament and of the Council\nof 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2012\nand (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/193718, and in particular\nArticle 62(5), third subparagraph, thereof,\nWhereas:\n(1) The information to be provided in an application for authorisation as crypto-asset service\nprovider should be sufficiently detailed and comprehensive to enable competent\nauthorities to assess whether an applicant meets the applicable requirements laid down\nin Title V and, where relevant, Title VI of Regulation (EU) 2023/1114."}, {"chunk_id": "a7dacedbb913f57b::65b::f4de", "source_doc": "FinalReport_MiCA_CP2.pdf", "page": null, "passage": "8.7 Annex VII: Draft RTS pursuant to Article 68(10)(b) of MiCA\nCOMMISSION DELEGATED REGULATION (EU) 2024/...\nof XXX\nsupplementing Regulation (EU) 2023/1114 of the European Parliament and of the\nCouncil with regard to regulatory technical standards specifying records to be kept of\nall crypto-asset services, activities, orders and transactions undertaken\nTHE EUROPEAN COMMISSION,\nHaving regard to the Treaty on the Functioning of the European Union,\nHaving regard to Regulation (EU) 2023/1114 of the European Parliament and of the Council\nof 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2010\nand (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/193774, and in particular\nArticle 68(10), first subparagraph, point (b) thereof,\nWhereas:\n(1) The records a crypto-asset service provider is required to keep should be adapted to the\ntype of business and the range of crypto-asset services, activities, orders, and\ntransactions undertaken by them, provided that the record-keeping obligations set out in\nRegulation (EU) 2023/1114, Regulation (EU) [Delegated Regulation xx/xxx on RTS on\ncomplaints handling], Regulation (EU) [Delegated Regulation xx/xxx RTS on conflicts of\ninterest], Regulation (EU) 2023/1113 and this Regulation are fulfilled and that competent\nauthorities are able to fulfil their supervisory tasks and take enforcement measures in\nview of ensuring both investor protection and market integrity. (2) Crypto-asset service providers should be free to determine the manner in which they\nkeep records of relevant data relating to all orders and transactions in crypto-assets."}], "evidence_b": [{"chunk_id": "fbadc7107ca6b841::588::c0fc", "source_doc": "Corporations_Act_2001_Vol5.pdf", "page": 248, "passage": "Note 1: Failure to comply with this subsection is an offence (see\nsubsection 1311(1)). Note 2: Failure to comply with this subsection may also lead to civil liability\nunder section 1041I.\n1041H Misleading or deceptive conduct (civil liability only)\n(1) A person must not, in this jurisdiction, engage in conduct, in\nrelation to a financial product or a financial service, that is\nmisleading or deceptive or is likely to mislead or deceive. Note 1: Failure to comply with this subsection is not an offence. Note 2: Failure to comply with this subsection may lead to civil liability under\nsection 1041I. For limits on, and relief from, liability under that\nsection, see Division 4. (2) The reference in subsection (1) to engaging in conduct in relation\nto a financial product includes (but is not limited to) any of the\nfollowing:\n(a) dealing in a financial product;\n(b) without limiting paragraph (a):\n(i) issuing a financial product;\n(ii) publishing a notice in relation to a financial product;\n(iii) making, or making an evaluation of, an offer under a\ntakeover bid or a recommendation relating to such an\noffer;\n(iv) applying to become a standard employer-sponsor of a\nsuperannuation entity;\n(v) permitting a person to become a standard\nemployer-sponsor of a superannuation entity;\n(vi) a trustee of a superannuation entity dealing with a\nbeneficiary of that entity as such a beneficiary;\nCorporations Act 2001 211"}, {"chunk_id": "fbadc7107ca6b841::524::bd15", "source_doc": "Corporations_Act_2001_Vol5.pdf", "page": 10, "passage": "Part 7.10-Market misconduct and other prohibited conduct\nrelating to financial products and financial services 204\nDivision 1-Preliminary 204\n1040A Content of Part................................................................204\n1040B Treat certain instruments as if they were financial\nproducts and Division 3 financial products....................204\nDivision 2-The prohibited conduct (other than insider trading\nprohibitions) 205\n1041A Market manipulation......................................................205\n1041B False trading and market rigging-creating a false\nor misleading appearance of active trading etc..............205\n1041C False trading and market rigging-artificially\nmaintaining etc. trading price.........................................207\n1041D Dissemination of information about illegal\ntransactions.....................................................................208\n1041E False or misleading statements.......................................209\n1041F Inducing persons to deal.................................................210\n1041G Dishonest conduct..........................................................211\n1041H Misleading or deceptive conduct (civil liability\nonly)................................................................................211\nviii Corporations Act 2001"}], "rationale": "EU_MICA_RTS (EU MiCA regulatory technical standards, including Article 84 qualifying-holding-acquisition information requirements — direct and indirect acquirers must submit detailed personal/corporate data to the home NCA) and AU_CORPS_ACT (Australian Corporations Act substantial-holdings disclosure under Chapter 6C — beneficial owners of 5%+ stakes in AU-listed entities must disclose to ASIC). When an entity acquires qualifying holdings in both EU CASPs and AU-listed financial entities, the two frameworks impose parallel notification obligations on materially the same persons. Operationally resolvable through parallel compliance with each notification regime; severity low because the obligations are reporting-only (not in direct contradiction).", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:58Z", "decision": "accept", "notes": "", "original_conflict_type": "operationally_resolvable", "original_severity": "low", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-05-25T23:35:57Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.55, "record_type": "non_conflict", "pair_id": "non_conflict:95f727931bb4e58f8f3495dc", "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_TTR_THRESHOLD", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU TTR Threshold"}, "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": "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): ASIC's crypto-asset INFO 225 / RG 282 guidance and AUSTRAC TTR $10k cash threshold reporting operate in disjoint regulatory domains at the obligation level. ASIC crypto vs AML threshold reporting — disjoint domains. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:4eae27c6756e243ce5d1f165", "label": "non_conflict", "regime_a": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "regime_b": {"regime_id": "SG_MAS_OUTSOURCING", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_OUTSOURCING"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "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."}, {"chunk_id": "a82833dc0f7ca903::17a::c743", "source_doc": "Outsourcing_Guidelines_2018.pdf", "page": 3, "passage": "1.2 These Guidelines1 on Outsourcing (\"Guidelines\") set out the Monetary Authority of\nSingapore's (\"MAS\") expectations of an institution that has entered into any outsourcing\narrangement or is planning to outsource its business activities2 to a service provider. An\ninstitution should conduct a self-assessment of all existing outsourcing arrangements against\nthese Guidelines3."}], "rationale": "MAS_TRM (MAS Technology Risk Management Guidelines) and SG_MAS_OUTSOURCING (MAS Outsourcing Guidelines). Both are MAS guidelines for SG financial institutions — TRM addresses ICT/tech risk, outsourcing addresses third-party arrangements. Coordinated parts of MAS's broader operational-risk supervisory architecture."}
{"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:6f5e6ce28a4829d57b18a2b2", "label": "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_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "conflict_type": "interpretive_fact_sensitive", "severity": "medium", "evidence_a": [{"chunk_id": "abc9007e907ef318::3c9::4151", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "A The proposed updates to INFO 225\nKey points\nInformation Sheet 225 Crypto-assets (INFO 225), as it is currently named,\nprovides guidance to persons offering products and services in relation to\ncrypto- and digital assets. It sets out our views regarding when a crypto- or\ndigital asset, or related product, may be a financial product. It also\ndiscusses when someone may be providing a financial service that requires\na licence from ASIC. We consider that now is an appropriate time to update INFO 225. Digital\nasset markets have evolved significantly in recent years, with many new\nproducts and services being offered. We propose to update INFO 225, subject to feedback from this\nconsultation. Draft updated INFO 225 includes a range of worked\nexamples. See the draft in the attachment to this consultation paper. Background to INFO 225\n1 Digital asset markets have evolved significantly over the last 10 to 15 years,\nsince the bitcoin white paper was first published."}, {"chunk_id": "abc9007e907ef318::5a2::9ff3", "source_doc": "CP_381_Updates_to_INFO225_Digital_Assets.pdf", "page": null, "passage": "CONSULTATION PAPER 381\nUpdates to INFO 225:\nDigital assets: Financial\nproducts and services\nDecember 2024\nAbout this paper\nThis consultation paper is about ASIC's guidance on digital assets and\nrelated products. It sets out our proposals to update Information Sheet 225 Crypto-assets\n(INFO 225) to provide further guidance about our interpretation of how the\nCorporations Act 2001 applies to crypto- and digital assets. It also sets out\nour proposals for licensing entities that provide financial services in relation\nto crypto- and digital assets that are financial products. Note: Draft updated Information Sheet 225 Digital assets: Financial products and services\nis available on our Consultations webpage under CP 381. About ASIC regulatory documents\nIn administering legislation ASIC issues the following types of regulatory\ndocuments. Consultation papers: seek feedback from stakeholders on matters ASIC\nis considering, such as proposed relief or proposed regulatory guidance. Regulatory guides: give guidance to regulated entities by:\n explaining when and how ASIC will exercise specific powers under\nlegislation (primarily the Corporations Act)\n explaining how ASIC interprets the law\n describing the principles underlying ASIC's approach\n giving practical guidance (e.g. describing the steps of a process such\nas applying for a licence or giving practical examples of how\nregulated entities may decide to meet their obligations)."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "rationale": "AU_ASIC_CRYPTO (ASIC INFO 225 — financial-product classification of crypto-assets under Corporations Act) and EU_MICA_TITLE_IV_EMT (EU MiCA Title IV — e-money token classification). Whether a given token is classified as a 'financial product' under AU law vs as an 'electronic money token' under EU MiCA turns on FACTS about the token's design, peg mechanism, and use — not pinned down in either regime. Different facts can produce different classifications and therefore different obligations.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:13Z", "decision": "accept", "notes": "", "original_conflict_type": "interpretive_fact_sensitive", "original_severity": "medium", "original_review_status": "single_annotation"}}
{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.84, "record_type": "non_conflict", "pair_id": "non_conflict:81c9bd95357c392884473944", "label": "non_conflict", "regime_a": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "MAS TRM Guidelines"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Notices", "short_name": "SG PSA DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "2b8959e883bd66cb::3c9::68aa", "source_doc": "Technology_Risk_Management_Guidelines_2021.pdf", "page": 5, "passage": "1.4 The revised MAS Technology Risk Management Guidelines set out technology\nrisk management principles and best practices for the financial sector, to guide FIs in the\nfollowing:\n(a) Establish Sound and Robust Technology Risk Governance and Oversight\nThe board of directors and senior management at an FI play an integral part in\nthe oversight and management of technology risk. The board of directors and\nsenior management should cultivate a strong risk culture, and ensure the\nestablishment of a sound and robust technology risk management framework.\n(b) Maintain Cyber Resilience\nStrong cyber resilience is critical for sustaining trust and confidence in financial\nservices. FIs should adopt a defence-in-depth approach to strengthening cyber\nresilience. It is also important that FIs establish and continuously improve their\nIT processes and controls to preserve confidentiality, integrity and availability of\ndata and IT systems.\nMonetary Authority of Singapore 5"}, {"chunk_id": "2b8959e883bd66cb::35f::55f8", "source_doc": "Technology_Risk_Management_Guidelines_2021.pdf", "page": 10, "passage": "3.4.1 The use of certain third party services by FIs may not always constitute\noutsourcing. However, as many of these services are provisioned or delivered using IT, or\nmay involve confidential or sensitive customer information being stored or processed\nelectronically by the third party, the FI's operations and its customers may be adversely\nimpacted if there is a system failure or security breach at the third party.\n\n3.4.2 The FI should assess and manage its exposure to technology risks that may affect\nthe confidentiality, integrity and availability of the IT systems and data at the third party\nbefore entering into a contractual agreement or partnership.\n\n3.4.3 On an ongoing basis, the FI should ensure the third party employs a high standard\nof care and diligence in protecting data confidentiality4 and integrity as well as ensuring\nsystem resilience."}], "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": "MAS TRM Guidelines and the SG PSA DPT regime co-apply to MAS-supervised DPT service providers but operate in disjoint domains. TRM governs technology risk management (ICT governance, outsourcing, cybersecurity); the PSA DPT regime governs payment-token service authorisation and AML/CFT controls. Obligations are cumulative — a DPT service provider must comply with both, but neither pushes against the other.", "would_conflict_if": ["TRM third-party outsourcing rules conflicted with PSA DPT licensee restrictions on outsourcing — both regimes treat outsourcing as a controlled activity with similar safeguards."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:31:45Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:81c9bd95357c392884473944", "label": "non_conflict", "regime_a": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "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": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}, {"chunk_id": "20d526d712753652::401::f956", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "One of the respondents requested for the F&P Guidelines to include sector-specific competencies\nand standardised self-assessment checklists which licensees can use in assessing the competence of\nrelevant persons as defined in the F&P Guidelines.\n8.5. Some respondents have also suggested to include case studies within the various guidelines which\nare specific to the DTSP industry. MAS' Response\n8.6. MAS would like to clarify that the TRM Guidelines are principles-based and set out statements of\nindustry best practices which financial institutions are expected to adopt. Licensees are required to\napply the principles in the TRM Guidelines in their risk assessments over its business and establish\neffective processes and controls to manage the identified risks.\n8.7. In relation to the F&P Guidelines, MAS would like to clarify that the F&P Guidelines provides a non-\nexhaustive list of factors which licensees should use in assessing the competence and capability of\nrelevant persons (as defined in the F&P Guidelines)."}], "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 MAS TRM passages discuss the application of general guidelines (TRM Guidelines, F&P Guidelines) to licensees and the inclusion of cybersecurity components for digital tokens. The SG_PSA_DPT passages discuss the issuance of a specific Notice (PSN02) under the Payment Services Act to holders of payment service licences providing digital payment token services, focusing on AML/CFT requirements and licensing. The regimes regulate different aspects of the digital token ecosystem: MAS TRM focuses on general licensing and operational guidelines, while SG_PSA_DPT focuses on specific AML/CFT obligations and licensing for DPT service providers. There is no specific obligation in MAS TRM that conflicts with a specific obligation in SG_PSA_DPT; rather, they address distinct regulatory domains."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:42:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:ecadbbaa8d1688ad115722b5", "label": "non_conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "evidence_b": [{"chunk_id": "20d526d712753652::404::80be", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "On 4 October 2024, the Monetary Authority of Singapore (\"MAS\") issued a consultation paper on\nthe proposed regulatory approach, regulations, notices and guidelines for digital token service\nproviders issued under the Financial Services and Markets Act 2022 (\"FSM Act\") (the \"consultation\npaper\"). Under this, digital token service providers are defined as individuals, partnerships or\nSingapore corporations that are operating from a place of business in Singapore or formed or\nincorporated in Singapore but carry on a business of providing digital token (\"DT\") services outside\nSingapore (\"DTSPs\").\n1.2. The consultation period closed on 4 November 2024, and MAS would like to thank all respondents\nfor their contributions. MAS has considered carefully the feedback received and incorporated them\nwhere justified and appropriate. Comments that are of a wider interest, together with MAS'\nresponses, are set out below. The list of respondents and their full submissions are provided in the\nAnnexes at the end of this paper.\n1.3."}], "rationale": "The EU_EMD2 passage (chunk 85307f9e2a040982::14a::134d) discusses the Digital Operational Resilience Act (DORA) and its application to the financial sector. The SG_FSMA_DTSP passage (chunk 20d526d712753652::404::80be) discusses the definition and licensing of Digital Token Service Providers (DTSPs) under the Financial Services and Markets Act 2022. The obligations regarding operational resilience (EU) and licensing of digital token service providers (SG) regulate distinct aspects of financial services operations and do not impose conflicting requirements on the same specific obligation. Therefore, the regimes are in different domains."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:37:59Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:609199f4655479a2e1f3a6c7", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DORA"}, "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": "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": "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 DORA regime regulates the digital operational resilience and ICT risk management of financial entities and their third-party service providers (chunk 85307f9e2a040982::5f2::974e). The SG_STABLECOIN regime regulates the issuance and reserve requirements of Single Currency Stablecoins (SCS) issued in Singapore (chunk 58f45cd2ef3de201::36c::e2f6). The obligations in DORA relate to the internal risk management and resilience of financial entities, whereas the obligations in SG_STABLECOIN relate to the asset backing and issuance of specific digital tokens. These are distinct regulatory domains; there is no specific obligation in DORA that conflicts with the specific obligations in SG_STABLECOIN regarding SCS issuance or reserve management."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:29:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:912517c22f9c4edb0d9066fd", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "SG_MAS_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "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": "6d8a84a9f3d6e9e4::480::ac46", "source_doc": "Guidelines_to_MAS_Notice_SFA04-N02_2025.pdf", "page": 5, "passage": "2 The FSM Sanctions Regulations include the regulations issued under section 192 read with sections 15(1)(b) and 219(d)\nof the FSM Act. Please refer to the following link for the FSM Sanctions Regulations:\nhttps://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions/regulations-for-targeted-financial-\nsanctions. Currently, the relevant FSM Sanctions Regulations are those relating to the Democratic People's Republic of\nKorea and Iran. concerns. Other support functions such as operations, human resource or\ntechnology also play a role to help mitigate the ML/TF risks that the CMI faces. The AML/CFT compliance function is typically the contact point regarding all\nAML/CFT issues for domestic and foreign authorities, including supervisory\nauthorities, law enforcement authorities and financial intelligence units.\n1-4-14 As the third line of defence, the CMI's internal audit function or an equivalent\nfunction plays an important role in independently evaluating the AML/CFT risk\nmanagement framework and controls for purposes of reporting to the audit\ncommittee of the CMI's board of directors, or a similar oversight body."}], "rationale": "The EU MICA Title IV EMT regime regulates the disclosure and liability obligations of issuers of e-money tokens and asset-referenced tokens (e.g., Article 51 and 52 regarding white papers and liability). The SG MAS AML General regime regulates Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) compliance, supervision of financial institutions and digital payment token (DPT) providers, and targeted financial sanctions. The obligations in the EU regime (disclosure of information to enable informed decisions) are distinct from the obligations in the SG regime (preventing money laundering and terrorism financing). There is no specific obligation in the EU regime that pushes against a specific obligation in the SG regime; rather, they regulate different domains of financial activity. Therefore, the regimes are in non-conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:52:16Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:ba520ca6213d7745f5af22c3", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "EU_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_AMLR_TFR"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "e6bb47e92e88e16c::567::36c4", "source_doc": "2023_Token_Mapping_Consultation_Paper.pdf", "page": null, "passage": "This paper represents a foundational step in the Government's multi-stage reform agenda that will\nimplement appropriate regulatory settings and support innovation. Token mapping plays a critical role in understanding the crypto ecosystem and ensuring a consistent\nand fair approach to the regulation of crypto assets in Australia. Primarily, this paper explores where\nexisting regulation applies and helps set the path for future reforms. Increased mainstream interest\nOver the past decade, there has been increased mainstream interest from both financial markets and\nconsumers in the crypto ecosystem. Over 1 million Australians are expected to include crypto assets\non their tax returns in FY 2022. This trend has created emerging risks and opportunities. According to Chainalysis' crypto adoption index, Australia ranks 40th globally for crypto adoption, with\nretail transactions at centralised exchanges also ranking 40th globally when measured by purchasing\npower parity per capita (see Figure 1).1\nFigure 1: Global crypto adoption index\nSource: Chainalysis September 2022\nFrom global market capitalisation highs of US$3.0 trillion (AU$4.1 trillion) in November 2021, crypto\nasset markets have lost around 63 per cent of their value and are now valued at US$1.0 trillion\n(AU$1.5 trillion).2 The turbulence in crypto asset markets over the past year highlights some of the\nrisks."}], "evidence_b": [{"chunk_id": "c0300673081f7232::279::1918", "source_doc": "DAC8_Directive_EU_2023-2226.pdf", "page": 2, "passage": "(8) The Union's anti-money laundering and countering the financing of terrorism framework (AML/CFT) extends the\nscope of obliged entities subject to AML/CFT rules to crypto-asset service providers regulated by Regulation\n(EU) 2023/1114. In addition, Regulation (EU) 2023/1113 of the European Parliament and of the Council(5)\nextends the obligation of payment service providers to accompany transfers of funds with information on the payer\nand the payee to crypto-asset service providers in order to ensure the traceability of transfers of crypto-assets for the\npurpose of fighting against money laundering and financing of terrorism."}], "rationale": "The Australian passages discuss the general tax treatment and adoption of crypto assets (chunk_id e6bb47e92e88e16c::567::36c4), while the EU passages focus on Anti-Money Laundering (AML) obligations for crypto-asset service providers (chunk_id c0300673081f7232::279::1918). The regimes regulate distinct aspects of the crypto ecosystem—taxation versus AML/CFT compliance—and do not impose conflicting obligations on the same specific activity. Therefore, the relationship is 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:c75308e59d10a691655963fe", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLA Regulation"}, "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": "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": "28dfda0f6a6539b6::49c::69f4", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 53, "passage": "Member States shall require that investment firms and market operators operating an MTF or an OTF establish,\npublish and maintain and implement transparent and non-discriminatory rules, based on objective criteria, governing\naccess to its facility.\n4. Member States shall require that investment firms and market operators operating an MTF or an OTF have\narrangements to identify clearly and manage the potential adverse consequences for the operation of the MTF or OTF,\nor for the members or participants and users, of any conflict of interest between the interest of the MTF, the OTF, their\nowners or the investment firm or market operator operating the MTF or OTF and the sound functioning of the MTF or\nOTF.\n5. Member States shall require that investment firms and market operators operating an MTF or OTF comply with\nArticles 48 and 49 and have in place all the necessary effective systems, procedures and arrangements to do so.\n6. Member States shall require that investment firms and market operators operating an MTF or an OTF clearly inform\nits members or participants of their respective responsibilities for the settlement of the transactions executed in that\nfacility."}], "rationale": "Bulk Tier-1 label (claude_sme_v1_bulk): EU AMLA Regulation establishing the AML supervisor and EU MiFID II investment-firm conduct directive operate in disjoint regulatory domains at the obligation level. AML supervisor vs investment-firm conduct rules — disjoint subject matters. Rubric walk performed at pattern-level rather than chunk-level: rule 1 ('can a single party satisfy both?') answered yes; rule 2 ('any obligation in A pushing against any obligation in B?') answered no. Confidence is deliberately low (~0.55–0.65) because the rubric was not applied by close reading of every chunk; human SME should re-litigate before this record is used in the training set.", "would_conflict_if": []}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:45:51Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:4cd168644c3ba5b2bc703eba", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "INT_IOSCO_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_IOSCO_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "491a2f0014d56ffb::702::05e4", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 71, "passage": "Article 52\nLiability of issuers of e-money tokens for the information given in a crypto-asset white paper\n1.\nWhere an issuer of an e-money token has infringed Article 51, by providing in its crypto-asset white paper or in a\nmodified crypto-asset white paper, information that is not complete, fair or clear, or that is misleading, that issuer and\nthe members of its administrative, management or supervisory body shall be liable to a holder of such e-money token\nfor any loss incurred due to that infringement.\n2.\nAny contractual exclusion or limitation of civil liability as referred to in paragraph 1 shall be deprived of legal\neffect.\n3.\nIt shall be the responsibility of the holder of the e-money token to present evidence indicating that the issuer of\nthat e-money token has infringed Article 51 by providing in its crypto-asset white paper or in a modified crypto-asset\nwhite paper information that is not complete, fair or clear, or that is misleading and that reliance on such information\nhad an impact on the holder's decision to purchase, sell or exchange that e-money token.\n4.\nThe issuer and the members of its administrative, management or supervisory bodies shall not be liable for loss\nsuffered as a result of reliance on the information provided in a summary pursuant to Article 51(6), including any\ntranslation thereof, except where the summary:\n(a) is misleading, inaccurate or inconsistent when read together with the other parts of the crypto-asset white paper; or\n(b) does not provide, when read together with the other parts of the crypto-asset white paper, key information in order\nto aid prospective holders when considering whether to purchase such e-money tokens.\n5.\nThis Article is without prejudice to any other civil liability pursuant to national law.\nEN\nL 150/110"}, {"chunk_id": "491a2f0014d56ffb::408::740e", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 69, "passage": "Issuers of e-money tokens shall notify their crypto-asset white paper to their competent authority at least 20\nworking days before the date of their publication. Competent authorities shall not require prior approval of crypto-asset white papers before their publication.\n12. Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the\nassessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers,\nnotified to the competent authorities and published on the issuers' websites.\n13. Before offering the e-money token to the public in the Union or seeking an admission to trading of the e-money\ntoken, the issuer of such e-money token shall publish a crypto-asset white paper on its website. EN\nL 150/109 14. The issuer of the e-money token shall together with the notification of the crypto-asset white paper pursuant to\nparagraph 11 of this Article provide the competent authority with the information referred to in Article 109(4)."}], "evidence_b": [{"chunk_id": "f173909614befd49::455::1a1a", "source_doc": "IOSCOPD562.pdf", "page": null, "passage": "See also Resolution of the Presidents' Committee on IOSCO Adoption of the\nObjectives and Principles of Securities Regulation, September 1998, available at\nhttp://www.iosco.org/library/resolutions/pdf/IOSCORES16.pdf.\n10 A full numerical list of IOSCO Resolutions and public reports is set out on IOSCO's\nwebsite:https://www.iosco.org/about/?subsection=resolutions and\nhttp://www.iosco.org/publications/?subsection=public_reports (respectively), catalogued by reference to\nthe month and year of their issuance. INTRODUCTION\nThe IOSCO Principles are one of the key standards and codes (including those on clearing and\nsettlement) highlighted by the Financial Stability Board (FSB) as being key to sound financial\nsystems and deserving priority implementation.11 Further articulation of how to apply the\nPrinciples pursuant to this Methodology helps to effectuate the general objectives of IOSCO\nas expressed in its By-Laws, in particular that securities authorities should cooperate to ensure\nbetter regulation of the markets on the domestic and international level by establishing\nstandards, among other things."}], "rationale": "The EU MICA Title IV EMT passages regulate the specific disclosure obligations of issuers of e-money tokens, including the content of crypto-asset white papers and liability for misleading information (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). The INT IOSCO GENERAL passages provide a general methodology and list of international standards and reports, including resolutions and technical committee reports on disclosure and securities regulation (chunk_id f173909614befd49::455::1a1a). The IOSCO documents do not impose specific, binding obligations on issuers of e-money tokens; rather, they serve as a framework of principles and international standards. Therefore, the regimes regulate different domains: EU MICA imposes specific regulatory requirements, while INT IOSCO provides general international guidance. There is no specific obligation in IOSCO that conflicts with the specific obligations in EU MICA."}
{"annotator_id": 10116, "annotated_at": "2026-05-25T23:50:38Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.68, "record_type": "conflict", "pair_id": "conflict:b831f4a86fc69eb698eac2d6", "label": "conflict", "regime_a": {"regime_id": "EU_GDPR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "GDPR"}, "regime_b": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "MiCA Title IV (EMT)"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "bd84e63f5b622b73::4a6::7573", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 1, "passage": "Consistent and\nhomogenous application of the rules for the protection of the fundamental rights and freedoms of natural\npersons with regard to the processing of personal data should be ensured throughout the Union. Regarding the\nprocessing of personal data for compliance with a legal obligation, for the performance of a task carried out in\nthe public interest or in the exercise of official authority vested in the controller, Member States should be\nallowed to maintain or introduce national provisions to further specify the application of the rules of this\nRegulation. In conjunction with the general and horizontal law on data protection implementing Directive\n95/46/EC, Member States have several sector-specific laws in areas that need more specific provisions. This\nRegulation also provides a margin of manoeuvre for Member States to specify its rules, including for the\nprocessing of special categories of personal data ('sensitive data'). To that extent, this Regulation does not exclude\nMember State law that sets out the circumstances for specific processing situations, including determining more\nprecisely the conditions under which the processing of personal data is lawful."}, {"chunk_id": "bd84e63f5b622b73::304::fe8e", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 60, "passage": "Article 44\nGeneral principle for transfers\nAny transfer of personal data which are undergoing processing or are intended for processing after transfer to a third\ncountry or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the\nconditions laid down in this Chapter are complied with by the controller and processor, including for onward transfers\nof personal data from the third country or an international organisation to another third country or to another internat\nional organisation. All provisions in this Chapter shall be applied in order to ensure that the level of protection of\nnatural persons guaranteed by this Regulation is not undermined.\n\n4.5.2016 EN Official Journal of the European Union L 119/61"}, {"chunk_id": "bd84e63f5b622b73::5e9::a119", "source_doc": "GDPR_Regulation_EU_2016-679.pdf", "page": 48, "passage": "Article 25\nData protection by design and by default\n1. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of\nprocessing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the\nprocessing, the controller shall, both at the time of the determination of the means for processing and at the time of the\nprocessing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are\ndesigned to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the\nnecessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of\ndata subjects.\n2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default,\nonly personal data which are necessary for each specific purpose of the processing are processed. That obligation applies\nto the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility.\nIn particular, such measures shall ensure that by default personal data are not made accessible without the individual's\nintervention to an indefinite number of natural persons.\n3. An approved certification mechanism pursuant to Article 42 may be used as an element to demonstrate\ncompliance with the requirements set out in paragraphs 1 and 2 of this Article."}], "evidence_b": [{"chunk_id": "491a2f0014d56ffb::53d::70f2", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 13, "passage": "(66)\nIssuers of e-money tokens should be authorised either as a credit institution under Directive 2013/36/EU or as an\nelectronic money institution under Directive 2009/110/EC. E-money tokens should be deemed to be 'electronic\nmoney' as that term is defined in Directive 2009/110/EC and their issuers should, unless specified otherwise in\nthis Regulation, comply with the relevant requirements set out in Directive 2009/110/EC for the taking up,\npursuit and prudential supervision of the business of electronic money institutions and the requirements on\nissuance and redeemability of e-money tokens. Issuers of e-money tokens should draw up a crypto-asset white\npaper and notify it to their competent authority. Exemptions regarding limited networks, regarding certain\ntransactions by providers of electronic communications networks and regarding electronic money institutions\nissuing only a limited maximum amount of electronic money, based on the optional exemptions specified in\nDirective 2009/110/EC, should also apply to e-money tokens. However, issuers of e-money tokens should still be\nrequired to draw up a crypto-asset white paper in order to inform buyers about the characteristics and risks of\nthe e-money tokens and should also be required to notify the crypto-asset white paper to the competent authority\nbefore its publication."}, {"chunk_id": "491a2f0014d56ffb::321::0923", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 74, "passage": "Article 57\nVoluntary classification of e-money tokens as significant e-money tokens\n1.\nAn issuer of an e-money token, authorised as a credit institution or as an electronic money institution, or applying\nfor such authorisation, may indicate that it wishes for its e-money token to be classified as a significant e-money token.\nIn that case, the competent authority shall immediately notify such request of the issuer to EBA, to the ECB and, in the\ncases referred to in Article 56(3), second subparagraph, to the central bank of the Member State concerned.\nIn order for the e-money token to be classified as significant under this Article, the issuer of the e-money token shall\ndemonstrate, through a detailed programme of operations, that it is likely to meet at least three of the criteria set out in"}, {"chunk_id": "491a2f0014d56ffb::3f8::b0ef", "source_doc": "MiCA_Regulation_EU_2023-1114.pdf", "page": 68, "passage": "Article 49\nIssuance and redeemability of e-money tokens\n1.\nBy way of derogation from Article 11 of Directive 2009/110/EC, in respect of the issuance and redeemability of e-\nmoney tokens only the requirements set out in this Article shall apply to issuers of e-money tokens.\n2.\nHolders of e-money tokens shall have a claim against the issuers of those e-money tokens.\n3.\nIssuers of e-money tokens shall issue e-money tokens at par value and on the receipt of funds.\nEN\nL 150/107\n\n4.\nUpon request by a holder of an e-money token, the issuer of that e-money token shall redeem it, at any time and\nat par value, by paying in funds, other than electronic money, the monetary value of the e-money token held to the\nholder of the e-money token.\n5.\nIssuers of e-money tokens shall prominently state the conditions for redemption in the crypto-asset white paper as\nreferred to in Article 51(1), first subparagraph, point (d).\n6.\nWithout prejudice to Article 46, the redemption of e-money tokens shall not be subject to a fee."}], "rationale": "EMT issuers under MiCA Title IV (operating as credit institutions or EMIs) process customer personal data for issuance, redemption-at-par (Article 49) and reserve-asset management, plus the prudential-supervisor reporting cycle. GDPR data minimisation, purpose limitation and cross-border transfer rules apply to all of this processing. The tension is operational: GDPR Article 6(1)(b)/(c) supplies the lawful basis for issuance-redemption customer processing, and the underlying EMD2 / CRD IV authorisation provides the parent framework. Practitioners must integrate the EMT-specific redemption obligations with GDPR purpose-specification and retention limits. Severity medium because the personal-data surface for EMT issuers is meaningful but more contained than for full-CASP operations.", "compliant_paths": ["Use Art. 6(1)(b) (contract) for issuance/redemption customer processing under MiCA Art 49.", "Use Art. 6(1)(c) (legal obligation) for supervisory-reporting personal data.", "Integrate EMT redemption record-keeping with GDPR Art 5(1)(e) retention windows tied to the AML record-retention chain."], "out_of_scope_assumptions": ["EMT issuer is EU-authorised as a credit institution or EMI; non-EU EMT issuance is structurally blocked (separate structural conflict labelled)."]}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:31:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.75, "record_type": "non_conflict", "pair_id": "non_conflict:98484968c8b9be6efbfcf518", "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_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "f296a7e0bead93df::4a5::9828", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": null, "passage": "Prudential Standard CPS 230\nOperational Risk Management\nObjectives and key requirements of this Prudential\nStandard\nThe aim of this Prudential Standard is to ensure that an APRA-regulated entity is\nresilient to operational risks and disruptions. An APRA-regulated entity must\neffectively manage its operational risks, maintain its critical operations through\ndisruptions, and manage the risks arising from service providers.\nAn APRA-regulated entity's approach to operational risk must be appropriate to its\nsize, business mix and complexity. The key requirements of this Prudential Standard\nare that an APRA-regulated entity must:\n• identify, assess and manage its operational risks, with effective internal\ncontrols, monitoring and remediation;\n• be able to continue to deliver its critical operations within tolerance levels\nthrough severe disruptions, with a credible business continuity plan (BCP); and\n• effectively manage the risks associated with service providers, with a\ncomprehensive service provider management policy, formal agreements and\nrobust monitoring.\nCPS 230 - 1\n\nAuthority\n1. This Prudential Standard is made under:\nsection 11AF of the Banking Act 1959 (Banking Act);"}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "evidence_b": [{"chunk_id": "09d4b93e8abbf71e::30f::2f9c", "source_doc": "RG_105_AFS_Organisational_Competence.pdf", "page": 18, "passage": "RG 105.62 We will accept a standard set by APRA if you are a body regulated by APRA\nand the standard is relevant to your responsible manager's role. For example,\nif you are a general insurer regulated by APRA, we will accept that a person\nwho is a 'responsible person' for the purposes of APRA's Prudential Standard\nCPS 520 Fit and proper has appropriate knowledge about dealing in general\ninsurance products.\nOption 2: Individual assessment\n\nRG 105.63 Individual assessment means an assessment of a person's capability to\nundertake their current duties, taking into account their previous work\nexperience. This type of assessment does not necessarily include a formal\nwritten examination. It may take the form of an oral or practical test, on-the-\njob assessment or some other form."}], "rationale": "AU_APRA_CPS230 (APRA Operational Risk Management prudential standard for AU-regulated entities) and SG_PSA_GENERAL (Singapore Payment Services Act — note: B-side citation is RG 105 which is actually AU not SG; cross-jur retrieval mismatch). Even setting aside the retrieval issue, both broadly touch on regulated entity operational requirements but in materially different perimeters — APRA's prudential standards for AU-regulated entities vs SG's payment-service licensing."}
{"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:e1c60bd048582a6b93707b13", "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_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "PSD2"}, "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::743::1b5f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 23, "passage": "Article 16\nDetection of missing information on the originator or the beneficiary\n1.\nThe crypto-asset service provider of the beneficiary shall implement effective procedures, including, where appro\npriate, monitoring after or during the transfers, in order to detect whether the information referred to in Article 14(1)\nand (2) on the originator and the beneficiary is included in, or follows, the transfer or batch file transfer of crypto-assets.\n2.\nIn the case of a transfer of crypto-assets made from a self-hosted address, the crypto-asset service provider of the\nbeneficiary shall obtain and hold the information referred to in Article 14(1) and (2) and shall ensure that the transfer of\ncrypto-assets can be individually identified.\nWithout prejudice to specific risk mitigating measures taken in accordance with Article 19b of Directive (EU) 2015/849,\nin the case of a transfer of an amount exceeding EUR 1 000 from a self-hosted address, the crypto-asset service provider\nof the beneficiary shall take adequate measures to assess whether that address is owned or controlled by the beneficiary.\n3.\nBefore making the crypto-assets available to the beneficiary, the crypto-asset service provider of the beneficiary\nshall verify the accuracy of the information on the beneficiary referred to in Article 14(2) on the basis of documents,\ndata or information obtained from a reliable and independent source.\n4.\nVerification as referred to in paragraphs 2 and 3 of this Article shall be deemed to have taken place where one of\nthe following applies:\n(a) the identity of the beneficiary has been verified in accordance with Article 13 of Directive (EU) 2015/849 and the\ninformation obtained pursuant to that verification has been retained in accordance with Article 40 of that Directive;\n(b) Article 14(5) of Directive (EU) 2015/849 applies to the beneficiary."}], "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::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 EU TFR explicitly applies to payment service providers and crypto-asset service providers; PSD2 authorises and regulates the same PSPs. The two regimes layer cleanly: PSD2 supplies the payments-conduct overlay (authorisation, SCA, open banking); AMLR/TFR supplies the AML / travel-rule overlay on top. No obligation in one pushes against any obligation in the other; a PSP must comply with both, but the obligations are cumulative.", "would_conflict_if": ["PSD2 SCA rules required disclosure of authentication details that AMLR confidentiality limited — designed as separate compliance surfaces."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:37:26Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:476f70712ca8f2e2f1672ff2", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "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": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "ba862e1f095bceac::1a6::1f0e", "source_doc": "FATF Recommendations 2012.pdf.coredownload.inline.pdf", "page": 79, "passage": "4. A country need not impose a separate licensing or registration system with respect to natural\nor legal persons already licensed or registered as financial institutions (as defined by the FATF\nRecommendations) within that country, which, under such license or registration, are\npermitted to perform VASP activities and which are already subject to the full range of\napplicable obligations under the FATF Recommendations."}], "evidence_b": [{"chunk_id": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The FATF Standards (Regime A) establish a minimum standard and allow countries to extend their regimes beyond the FATF definition of a VASP (chunk 85240528438654b9::1cd::07d7, chunk 94). The Singapore foundational legislation (Regime B) explicitly references the FATF standards and indicates an intention to expand the scope of legislation to align with international AML/CFT requirements (chunk b49627bb889ef1d9::3ef::7168, chunk d6f4be6b9d136778::467::12af). Furthermore, the FATF guidance notes that countries need not impose a separate licensing system for entities already licensed as financial institutions (chunk ba862e1f095bceac::1a6::1f0e). These passages demonstrate that the regimes are aligned and complementary, with Singapore seeking to implement the FATF standards rather than conflict with them."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:43:18Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:3d9787bec6107088bff47d81", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "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": "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": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The EU DAC8 regime focuses on tax transparency and the automatic exchange of information regarding crypto-asset users (chunk_ids c0300673081f7232::320::7b46, c0300673081f7232::498::163c). In contrast, the SG Foundational Legislation passages describe MAS's enforcement actions against ICO issuers and exchanges for regulatory breaches, and its intention to align with international AML/CFT standards (chunk_ids b49627bb889ef1d9::3ef::7168, d6f4be6b9d136778::467::12af). These obligations regulate different domains—tax reporting versus market conduct and AML enforcement—and do not impose conflicting requirements on the same specific activity."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:26:49Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:0a8446ecbba0eb98c6a56170", "label": "non_conflict", "regime_a": {"regime_id": "EU_DAC8", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_DAC8"}, "regime_b": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "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": "fe52dd87e13dba41::261::59a4", "source_doc": "Guidance-RBA-NPPS.pdf.coredownload.pdf", "page": 5, "passage": "1 See FATF (2006), FATF (2008) and FATF (2010).\n\n2 See FATF (2013a). This document outlines general principles that may serve as a useful framework in\nassessing ML/TF risks at the national level. However, these principles may also relevant when\nconducting risk assessments of a more focussed scope. The guidance is also not intended to describe\nhow supervisors should assess risks in the context of risk-based supervision.\n\n3 See FATF (2013b).\n 2013 3\n\nexclusion could undermine the effectiveness of an AML/CFT regime hence, financial inclusion and\nAML/CFT should be seen as serving complementary objectives."}], "rationale": "The EU DAC8 regime focuses on tax transparency and the automatic exchange of information regarding crypto-asset users (Recital 19, 498, 3d8). The INT_FATF_GENERAL regime focuses on anti-money laundering (AML) and counter-terrorist financing (CFT) standards, risk assessment, and the supervision of financial institutions (Recital 59a4, 4ad, 215). The cited passages from FATF discuss general principles for assessing ML/TF risks and the global standard for AML/CFT, which are distinct from the specific tax reporting obligations of DAC8. While both regimes apply to the crypto-asset sector, they regulate different domains (tax transparency vs. financial crime prevention) and do not impose conflicting obligations on the same specific action."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:08:44Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:45712b2f1083d787ba743231", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_IV_EMT", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_IV_EMT"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "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": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "ba862e1f095bceac::1a6::1f0e", "source_doc": "FATF Recommendations 2012.pdf.coredownload.inline.pdf", "page": 79, "passage": "4. A country need not impose a separate licensing or registration system with respect to natural\nor legal persons already licensed or registered as financial institutions (as defined by the FATF\nRecommendations) within that country, which, under such license or registration, are\npermitted to perform VASP activities and which are already subject to the full range of\napplicable obligations under the FATF Recommendations."}], "rationale": "The EU MICA Title IV EMT passages regulate the disclosure and liability obligations of issuers of e-money tokens, specifically regarding the content of crypto-asset white papers and notification to competent authorities (chunk_ids 491a2f0014d56ffb::702::05e4, 491a2f0014d56ffb::408::740e). In contrast, the FATF VASP passages focus on the definition of Virtual Asset Service Providers (VASPs) and the application of AML/CFT standards, noting that countries may extend their regimes beyond the minimum FATF standard and that existing financial institution licenses may cover VASP activities (chunk_ids 85240528438654b9::1cd::07d7, ba862e1f095bceac::1a6::1f0e). The obligations in the EU regime relate to product disclosure and issuer liability, while the FATF regime relates to the licensing and AML/CFT obligations of service providers. These are distinct regulatory domains that do not impose conflicting obligations on the same specific activity."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:35:24Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:66c7b1505f3316831b261906", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_GENERAL"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "08b3db1cc7362f25::3bb::5dba", "source_doc": "Guidance-Correspondent-Banking-Services.pdf.coredownload.pdf", "page": null, "passage": "FATF GUIDANCE\nCORRESPONDENT\nBANKING SERVICES\nOCTOBER 2016 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes\npolicies to protect the global financial system against money laundering, terrorist financing and the financing of\nproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money\nlaundering (AML) and counter-terrorist financing (CFT) standard.\nwww.fatf-gafi.org\nFor more information about the FATF, please visit\nThis document and/or any map included herein are without prejudice to the status of or sovereignty over any\nterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Citing reference:\nGuidance on correspondent banking services,\nFATF (2016), FATF, Paris\nwww.fatf-gafi.org/publications/fatfrecommendations/documents/correspondent-banking-services.html\n© 2016 FATF/OECD."}], "evidence_b": [{"chunk_id": "20d526d712753652::1a4::2e6e", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Notabene commend's the Monetary Authority of Singapore (MAS) for proposing a\ncomprehensive and detailed regulatory approach for Digital Token Service Providers\n(DTSPs) under the Financial Services and Markets Act 2022. Our comments focus on\nthe alignment of these notices and guidelines with international standards,\nparticularly in light of Financial Action Task Force (FATF) Recommendations,\nincluding the Travel Rule."}, {"chunk_id": "20d526d712753652::4b9::b812", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": 71, "passage": "(Please refer to paragraph 12 of the draft FSM Notice). The proposed requirements for Correspondent Account Services (CAS) in paragraph\n5.6 of the draft FSM Notice are both applicable and appropriate for the digital token\nservice provider (DTSP) sector. Given the inherent cross-border nature and rapid\ntransactions within digital token services, the FATF-aligned risk mitigation measures\nensure that DTSPs are aligned with global AML/CFT standards, providing a secure\nframework for correspondent services while addressing potential ML/TF risks. Applicability of Risk Mitigation Measures\nThe requirement for DTSPs to assess the suitability of financial institutions when\nproviding or receiving CAS, including evaluating their AML/CFT controls, is essential\nfor preventing potential misuse of these services. The dynamic and often cross-\njurisdictional interactions in digital token services make these standards particularly\nrelevant to ensuring consistent risk management. MAS could consider offering\nguidance on specific factors DTSPs should evaluate, such as transaction monitoring\ncapabilities and the jurisdiction's regulatory reputation, to better equip licensees in\napplying a comprehensive assessment."}], "rationale": "The FATF passages (Regime A) provide general international standards for AML/CFT and correspondent banking services. The Singapore DTSP passages (Regime B) describe the licensing and regulatory framework for Digital Token Service Providers (DTSPs) and explicitly state that the proposed regulations are aligned with international standards, including FATF Recommendations. Specifically, Regime B cites the FATF Travel Rule and notes that FATF-aligned risk mitigation measures are being applied to ensure DTSPs are aligned with global AML/CFT standards. There is no evidence of a specific obligation in Regime A that conflicts with a specific obligation in Regime B; rather, Regime B confirms it is implementing Regime A standards."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:04:55Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:5daae0b495a5816672290cc1", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "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": "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": "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 Australian regime (AU_ATO_CRYPTO) focuses on the taxation of crypto assets and the regulatory framework for their treatment, including token mapping and consumer interest (chunk_id e6bb47e92e88e16c::567::36c4). The European regime (EU_MAR) establishes a common regulatory framework for market abuse, specifically insider dealing and market manipulation in financial instruments (chunk_id 5cc4a27bc578287a::165::3333). The obligations and subject matter of the two regimes are distinct; one governs tax compliance and asset classification, while the other governs market integrity and conduct. There is no specific obligation in the Australian tax regime that conflicts with the European market abuse regime."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:14:27Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:77ed484abd9ab804908d4be4", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "regime_b": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "550958b067dc6726::709::b159", "source_doc": "2023_Regulating_Digital_Asset_Platforms_Proposal.pdf", "page": 15, "passage": "2.3 Overview of proposed framework\nLicensing\nThe proposed framework would recognise certain asset holding arrangements as a financial product (a\ndigital asset facility). The existing AFSL framework would apply to any person 'carrying on a financial\nservices business in Australia' in relation to a digital asset facility. Examples of 'financial services'\ninclude:\n• dealing in a financial product (including applying for or acquiring, issuing, varying or disposing of a\nfinancial product)\n• making a market for a financial product\n• providing a custodial or depository service, and\n• providing financial product advice.\nThe issuer of a digital asset facility would be the person or persons responsible for the obligations\nowed to customers under the terms of the asset holding arrangement (platform provider). Platform\nproviders and other intermediaries performing financial services in relation to digital asset facilities\n(e.g. brokers, arrangers, agents, market makers, and advisers) would be required to hold an AFSL.\nWhile the application of the AFSL regime would be jurisdictionally limited to Australia in the usual way,\nan intermediary business in Australia, like a broker, would need to be licensed to provide services that\ninvolve dealing in digital asset facilities generally (including those not licensed or located in Australia).\nSee Part 3 for further detail about licensing obligations.\nFacility contracts\nThe proposed framework would permit digital asset facilities to be paired with other functions,\ncreating digital asset platforms. All arrangements involving digital asset facilities would be required to\nbe structured as non-discretionary arrangements.29 The term 'non-discretionary' means the\narrangements must operate according to pre-agreed and transparent rules and procedures."}], "evidence_b": [{"chunk_id": "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_ASIC_AFSL regime regulates the licensing and conduct of financial services providers (specifically platform providers and intermediaries) in Australia, focusing on financial product obligations and AFSL requirements (chunk 550958b067dc6726::709::b159). The EU_AMLA regime establishes an institutional framework for Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations across the European Union (chunk df546f2364aaf9e2::25a::6ab3). The obligations in the AMLA text relate to cooperation with authorities, information exchange, and supervisory powers, which are distinct from the financial services licensing and conduct obligations detailed in the AFSL text. Therefore, the regimes regulate different domains and do not impose conflicting obligations."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T17:00:48Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:43b23af590493e8e87ef6d9a", "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_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "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": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}], "rationale": "The evidence from APRA CPS 230 focuses on operational risk management, business continuity, and the management of service providers to ensure resilience (chunk_ids f296a7e0bead93df::4a5::9828, 4b6fab404e7acfca::3d7::737c). The evidence from the Singapore Stablecoin regime focuses on the regulatory perimeter for Single-Currency Stablecoins (SCS), distinguishing them from other digital payment tokens and outlining the scope of MAS' regulatory approach (chunk_ids 58f45cd2ef3de201::36c::e2f6, 33d059aa86716ddd::4ed::8511). The obligations in CPS 230 regarding operational resilience and service provider management do not directly oppose the Singapore regime's classification of SCS or its proposed reserve asset requirements. Therefore, the regimes regulate different domains and do not 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:38858a8ae5b8ef70ce9b468a", "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_AMLR_TFR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "AMLR + TFR"}, "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": "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"}], "evidence_b": [{"chunk_id": "d7502c011527b67c::511::093f", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 21, "passage": "EN\nL 150/21 2. The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by\nthe following information on the beneficiary:\n(a) the name of the beneficiary;\n(b) the beneficiary's distributed ledger address, in cases where a transfer of crypto-assets is registered on a network using\nDLT or similar technology, and the beneficiary's crypto-asset account number, where such an account exists and is\nused to process the transaction;\n(c) the beneficiary's crypto-asset account number, in cases where a transfer of crypto-assets is not registered on a\nnetwork using DLT or similar technology; and\n(d) subject to the existence of the necessary field in the relevant message format, and where provided by the originator\nto its crypto-asset service provider, the current LEI or, in its absence, any other available equivalent official identifier\nof the beneficiary.\n3. By way of derogation from paragraph 1, point (c), and paragraph 2, point (c), in the case of a transfer of crypto-\nassets not registered on a network using DLT or similar technology and not made to or from a crypto-asset account, the\ncrypto-asset service provider of the originator shall ensure that the transfer of crypto-assets is accompanied by a unique\ntransaction identifier.\n4."}, {"chunk_id": "d7502c011527b67c::1a0::faa6", "source_doc": "TFR_Regulation_EU_2023-1113.pdf", "page": 24, "passage": "Article 19\nRetention of information on the originator and the beneficiary accompanying the transfer\nIntermediary crypto-asset service providers shall ensure that all the information received on the originator and the\nbeneficiary that accompanies a transfer of crypto-assets is transmitted with the transfer and that records of such\ninformation are retained and made available on request to the competent authorities."}], "rationale": "AUSTRAC's TTR threshold regime is a domestic Australian cash-transaction reporting obligation tied to the A$10,000 threshold. The EU TFR is a crypto-asset and fiat wire-transfer travel-rule regime for EU CASPs and PSPs. The two regimes operate in different jurisdictions and address different transaction types (cash threshold vs wire-transfer information). No obligation collision possible. Hard negative.", "would_conflict_if": ["An Australian-EU dual-regulated entity processed transactions hitting both regimes — they would apply cumulatively on their respective jurisdictional surfaces."]}
{"annotator_id": 10116, "annotated_at": "2026-05-25T22:55:36Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:b2f7e79d3c53218ebfd4f524", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU AML/CTF"}, "regime_b": {"regime_id": "AU_APRA_CPS230", "jurisdiction": "Australia", "issuing_body": "APRA", "short_name": "APRA CPS 230"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "86b8c938e66f203a::3a4::5db5", "source_doc": "AML rules 2007.pdf", "page": 214, "passage": "means to identify and verify the\nidentification of the customer if previously undertaken by the first\nreporting entity:\n(a) a prescribed verification procedure;\n(b) an identification reference; or\n(c) a procedure approved by the AUSTRAC CEO; and\n(d) any relevant identification obtained by the second reporting\nentity in regard to subparagraph 50.4(2)(a)-(c)(if applicable); or\n(3) collect any KYC information in respect of the customer; or\n(4) verify, from a reliable and independent source, KYC information that\nhas been obtained in respect of the customer;\nfor the purpose of enabling the second reporting entity to be reasonably\nsatisfied that the customer is the person that he or she claims to be.\n50.9 For the purposes of paragraph 50.8, the following circumstances are specified:\n(1) a suspicious matter reporting obligation arises in relation to the\ncustomer to which the second reporting entity has commenced to\nprovide a"}, {"chunk_id": "d38ec0ddcc912963::450::6872", "source_doc": "Reporting.pdf", "page": null, "passage": "'@ Australian Government Cee ee\nahem 8 eporting Home / Business / Core guidance / Reporting As a reporting entity you must report certain transactions and suspicious matters, and\nsubmit compliance reports to AUSTRAC. Everyone, including reporting entities, must\nreport cross-border movements of physical currency. Ongoing reporting obligations Threshold transaction reports You must submit threshold transaction reports (TTR) for transfers of A$10,000 or more\nin cash (or the foreign currency equivalent). TTRs are due within 10 business days after\nthe date of the transaction. International funds transfer instruction reports (IFTIs) You must submit international funds transfer instruction reports (IFTIs) for transfers of\nfunds of any value into or out of Australia, made either electronically or under a\ndesignated remittance arrangement. IFTIs are due within 10 business days after the\ntransfer instruction is sent or received. Suspicious matter reports (SMRs) You must submit suspicious matter reports (SMRs) when you have a suspicion that a\ncustomer or transaction is related to criminal activity."}], "evidence_b": [{"chunk_id": "f296a7e0bead93df::5e9::d5f4", "source_doc": "CPS_230_Operational_Risk_Management.pdf", "page": 2, "passage": "Operational risk is inherent\nin all products, activities, processes and systems.\n14. An APRA-regulated entity must, to the extent practicable, prevent disruption to\ncritical operations, adapt processes and systems to continue to operate within\ntolerance levels in the event of a disruption and return to normal operations\npromptly once a disruption is over.\n15. An APRA-regulated entity must not rely on a service provider unless it can ensure\nthat in doing so it can continue to meet its prudential obligations in full and\neffectively manage the associated risks. Risk management framework\n16. As part of its risk management framework required under Prudential Standard\nCPS 220 Risk Management (CPS 220) and Prudential Standard SPS 220 Risk\nManagement (SPS 220), an APRA-regulated entity must develop and maintain:\ngovernance arrangements for the oversight of operational risk;\nan assessment of its operational risk profile, with a defined risk appetite\nsupported by indicators, limits and tolerance levels;\ninternal controls that are designed and operating effectively for the\nmanagement of operational risks;\nappropriate monitoring, analysis and reporting of operational risks and\nescalation processes for operational incidents and events;\nbusiness continuity plan(s) (BCPs) that set out how the entity would\nidentify, manage and respond to a disruption within tolerance levels and are\nregularly tested with severe but plausible scenarios; and\nprocesses for the management of service provider arrangements.\n17."}, {"chunk_id": "4b6fab404e7acfca::3d7::737c", "source_doc": "CPG_230_Operational_Risk_Management_PG.pdf", "page": 5, "passage": "15. An APRA-regulated entity must not rely on a service provider unless it can ensure that in doing so it can\ncontinue to meet its prudential obligations in full and effectively manage the associated risks.\n\n1. The aim of CPS 230 is to ensure that APRA-regulated entities ('entities') are resilient to operational risks and\ndisruptions. Operational resilience is the outcome of prudent operational risk management: the ability to\neffectively manage and control operational risks; limit disruptions; and maintain critical operations through\ndisruptions.\n\n2. APRA expects that, in implementing CPS 230, a prudent entity would start with the identification of its critical\noperations. An entity would:\na) identify its critical operations (paragraph 36 of CPS 230 sets out the minimum list);\nb) set tolerance levels for disruption of these critical operations; and\nc) identify the processes and resources needed to deliver these critical operations, including material\nservice providers."}], "rationale": "AUSTRAC AML/CTF guidance covers customer due diligence, transaction monitoring and reporting; CPS 230 is the APRA operational-risk standard. The two regimes co-apply to APRA-regulated reporting entities but address disjoint subject matters. Operational-risk failures may have AML implications and vice versa, but the regimes' obligations are cumulative, not conflicting. Hard negative.", "would_conflict_if": ["CPS 230 BCP timelines required disruption of AML transaction monitoring during incident handling — designed to be coordinated."]}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:58:02Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:e748123499a722f5491baf4c", "label": "non_conflict", "regime_a": {"regime_id": "EU_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "regime_b": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "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": "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 MIFID2 passages regulate the conduct of investment firms, specifically regarding product governance, suitability assessments, and client information disclosure (e.g., Article 1 and Article 25). The FATF_R16 passages regulate Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) standards, focusing on digital identity and virtual assets. The obligations in MIFID2 regarding client suitability and information disclosure do not conflict with the FATF's AML/CFT obligations regarding customer due diligence or digital identity verification. Instead, they operate in complementary domains: MIFID2 ensures the suitability of financial instruments for the client, while FATF ensures the identity of the client to prevent financial crime. There is no specific obligation in MIFID2 that pushes against a specific obligation in FATF, nor is there evidence that one regime renders the other inapplicable."}
{"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:0d92dcd15cca6f6ca941a3bc", "label": "non_conflict", "regime_a": {"regime_id": "FATF_R16", "jurisdiction": "International", "issuing_body": "?", "short_name": "FATF_R16"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "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": "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": "FATF_R16 (FATF Recommendation 16 — international AML travel-rule standard) and INT_BASEL_GENERAL (Basel III prudential framework). Both are international standards bodies; FATF addresses AML/CFT, Basel addresses banking prudential. Coordinated pillars of international financial regulation."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:04:23Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:f0fc81499260b6c37b600e23", "label": "non_conflict", "regime_a": {"regime_id": "INT_BASEL_CRYPTO", "jurisdiction": "International", "issuing_body": "BASEL", "short_name": "INT_BASEL_CRYPTO"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "32afd37cade34f84::3a4::1a5b", "source_doc": "d424.pdf", "page": 11, "passage": "16. For the purposes of calculating capital requirements, a bank exposure is defined as a claim\n(including loans and senior debt instruments, unless considered as subordinated debt for the purposes of\nparagraph 53) on any financial institution that is licensed to take deposits from the public and is subject\nto appropriate prudential standards and level of supervision. 13 The treatment associated with\nsubordinated bank debt and equities is addressed in paragraphs 49 to 53.\nRisk weight determination\n\n17. Bank exposures will be risk-weighted based on the following hierarchy:14\n\n13 For internationally active banks, appropriate prudential standards (eg capital and liquidity requirements) and level of\nsupervision should be in accordance with the Basel framework. For domestic banks, appropriate prudential standards are\ndetermined by the national supervisors but should include at least a minimum regulatory capital requirement."}], "evidence_b": [{"chunk_id": "4b4c3c417dc293ba::185::f41d", "source_doc": "MAS_Notice_PSN02_original.pdf", "page": 1, "passage": "1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act\n(Cap. 186) (\"MAS Act\") and applies to all holders of a payment service licence under the\nPayment Services Act 2019 (Act 2 of 2019) (\"PS Act\") that carry on a business of\nproviding digital payment token service (\"payment service provider\").\n\n1.2 This Notice shall take effect from 28 January 2020."}], "rationale": "Regime A (INT_BASEL_CRYPTO) regulates the capital adequacy and risk-weighting of bank exposures to financial institutions, including securities firms and central counterparties. Regime B (SG_PSA_DPT) regulates the licensing and Anti-Money Laundering (AML) obligations of entities providing Digital Payment Token (DPT) services in Singapore. The obligations in Regime A relate to prudential capital standards for banking institutions, while the obligations in Regime B relate to the conduct and licensing of payment service providers. The passages confirm that these regimes govern distinct domains: one focuses on banking sector stability and capital requirements, while the other focuses on the AML/CFT compliance of digital payment token service providers. There is no specific obligation in Regime A that pushes against a specific obligation in Regime B."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T18:36:37Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:4e0cbbaa8b23bf6b202fecfc", "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_MIFID2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MIFID2"}, "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": "28dfda0f6a6539b6::514::0ca0", "source_doc": "MiFID2_Directive_EU_2014-65.pdf", "page": 57, "passage": "Article 24\nGeneral principles and information to clients\n1. Member States shall require that, when providing investment services or, where appropriate, ancillary services to\nclients, an investment firm act honestly, fairly and professionally in accordance with the best interests of its clients and\ncomply, in particular, with the principles set out in this Article and in Article 25.\n2. Investment firms which manufacture financial instruments for sale to clients shall ensure that those financial\ninstruments are designed to meet the needs of an identified target market of end clients within the relevant category\nof clients, the strategy for distribution of the financial instruments is compatible with the identified target market, and the\ninvestment firm takes reasonable steps to ensure that the financial instrument is distributed to the identified target\nmarket. An investment firm shall understand the financial instruments they offer or recommend, assess the compatibility of the\nfinancial instruments with the needs of the clients to whom it provides investment services, also taking account of the\nidentified target market of end clients as referred to in Article 16(3), and ensure that financial instruments are offered or\nrecommended only when this is in the interest of the client.\n3."}], "rationale": "The evidence from AU_FEDREG_AML (chunk cf7cefacba3f94bc::49a::f39e) outlines obligations for reporting entities regarding customer identification, suspicious activity reporting, and transaction monitoring. The evidence from EU_MIFID2 (chunk 28dfda0f6a6539b6::514::0ca0) outlines principles for investment firms regarding acting in the best interests of clients and ensuring financial instruments are designed to meet client needs. The obligations in the AML regime focus on preventing financial crime and monitoring transactions, while the MIFID II obligations focus on client suitability and product governance. These are distinct regulatory domains with no apparent overlap or conflict in obligations."}
{"annotator_id": 10116, "annotated_at": "2026-05-26T01:13:52Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.74, "record_type": "conflict", "pair_id": "conflict:1db01b584ce4e955c7539185", "label": "conflict", "regime_a": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG FSMA DTSP"}, "regime_b": {"regime_id": "AU_FEDREG_AML", "jurisdiction": "Australia", "issuing_body": "FederalRegister", "short_name": "AU AML/CTF Act + Rules"}, "conflict_type": "operationally_resolvable", "severity": "medium", "evidence_a": [{"chunk_id": "cc1be49e9cf8c821::2f4::ea8f", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "2.1 Pursuant to section 137 of the FSM Act, any person that conducts digital token\nservices in Singapore as defined in the First Schedule of the FSM Act is required to hold a\nlicence unless that person is exempted. Section 137(5) of the FSM Act sets out the applicable\nexemptions from holding a licence.\n\n2.2 As MAS will not be providing a transitional arrangement for DTSPs, DTSPs which are\nsubject to a licensing requirement under section 137 of the FSM Act must suspend or cease\ncarrying on a business of providing digital token services outside Singapore by 30 June 2025.\nA DTSP that contravenes the licensing requirement is guilty of an offence and would be liable\nto penalties set out in section 137(6) of the FSM Act.\nTypes of Digital Token Services"}, {"chunk_id": "cc1be49e9cf8c821::3fc::a271", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 3, "passage": "1.1 The Guidelines on Licensing for Digital Token Service Providers (the \"Guidelines\")\nare intended to provide guidance on the application procedures, licensing criteria and\nongoing requirements for Digital Token Service Providers under Part 9 of the Financial\nServices and Markets Act 2022 (the \"FSM Act\"). Under this, digital token service providers are\ndefined as individuals, partnerships or Singapore corporations that are operating from a place\nof business in Singapore or formed or incorporated in Singapore but carry on a business of\nproviding digital token services outside Singapore (\"DTSPs\").\n\n1.2 These Guidelines should be read in conjunction with the provisions of the FSM Act,\nthe Financial Services and Markets (Digital Token Service Provider) Regulations (the \"FSM\nRegulations\") and other relevant legislation, notices, guidelines and FAQs issued by the\nMonetary Authority of Singapore (\"MAS\").\n\n1.3 MAS will update these Guidelines periodically to provide further guidance.\n2. Licence under the FSM Act"}, {"chunk_id": "cc1be49e9cf8c821::58b::dc71", "source_doc": "Guidelines_Licensing_DTSP_FSMA_2022.pdf", "page": 4, "passage": "3.1 DTSPs are susceptible to higher money laundering, terrorism financing and\nproliferation financing (\"ML/TF\") risks due to the internet-based and cross-border nature of\nsuch services. This would result in a greater risk of such providers being engaged in or\nmisused for illicit purposes to the detriment of Singapore's reputation. In light of these risks,\nMAS approaches the licensing of DTSPs in a prudent and cautious manner, and there will be\nextremely limited circumstances under which MAS will consider granting an applicant a DTSP\nlicence under the FSM Act. The extremely limited circumstances include:\n• The applicant has a business model that makes economic sense, and is able to\ndemonstrate to MAS' satisfaction that it has valid reasons as to why it does not\nintend to carry on a business of providing digital token services in Singapore\ndespite operating in or being formed or incorporated in Singapore;\n• The applicant does not operate in a manner that is of concern to MAS and is\nalready regulated and supervised for its compliance with relevant internationally\nagreed standards, such as standards established by the Financial Stability\nBoard, the International Organisation of Securities Commissions and the\nFinancial Action Task Force (\"FATF\"); and\n• MAS does not have concerns with the business structure of the applicant in\nrelation to, for example, its ability to comply with regulatory obligations."}], "evidence_b": [{"chunk_id": "254ca2d92d196180::369::b111", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2 Identification procedures etc. Division 2 Identification procedures for certain pre-commencement customers\nSection 29\n(b) after the commencement of this section, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer. Note 1: For suspicious matter reporting obligation, see section 41. Note 2: For tipping-off offences, see section 123. Requirement\n(2) The reporting entity must:\n(a) take such action as is specified in the AML/CTF Rules; and\n(b) do so within the time limit allowed under the AML/CTF\nRules. Civil penalty\n(3) Subsection (2) is a civil penalty provision. Interpretation\n(4) For the purposes of this section, assume that Part 1 had been in\nforce at all material times before the commencement of this\nsection.\n80 Anti-Money Laundering and Counter-Terrorism Financing Act 2006 Identification procedures etc."}, {"chunk_id": "254ca2d92d196180::43c::0a91", "source_doc": "Anti-Money Laundering act 2006.pdf", "page": 98, "passage": "Part 2\nIdentification procedures for certain low-risk services Division 3\nSection 30\nDivision 3-Identification procedures for certain low-risk\nservices\n30 Identification procedures for certain low-risk services\nScope\n(1) This section applies to the provision by a reporting entity of a\ndesignated service to a customer if, under the AML/CTF Rules, the\nservice is taken to be a low-risk designated service. (2) Sections 32 and 34 do not apply to the provision by the reporting\nentity of the designated service to the customer. Note: For special rules about verification of identity etc., see section 31.\n31 Verification of identity of low-risk service customer etc. Scope\n(1) This section applies to a reporting entity if:\n(a) at a particular time (the relevant time), the reporting entity\ncommences to provide a designated service to a customer;\nand\n(b) under the AML/CTF Rules, the service is taken to be a\nlow-risk designated service; and\n(c) at the relevant time or a later time, a suspicious matter\nreporting obligation arises for the reporting entity in relation\nto the customer."}, {"chunk_id": "50f54f147dcb1cba::30a::639e", "source_doc": "AML_CTF_Rules_2007.pdf", "page": 103, "passage": "Note: Where a reporting entity is unable to ascertain whether the circumstances in\n19.3(17)(a) applies, the reporting entity can assume that the transaction was\ncarried out by the customer.\n19.4 If the threshold transaction arises under a designated service that is of a kind\ndescribed in item 3 of table 1 in subsection 6(2) of the AML/CTF Act, the\nreference to 'customer' in subparagraphs 19.3(2) to 19.3(14) inclusive will\nbe taken, in the first instance, to refer only to the holder of the account and\nthe signatory (if any) conducting the transaction in relation to the account,\nprovided that:\n(1) if there are other signatories to the account, the AUSTRAC CEO may\nrequire the reporting entity to give to the AUSTRAC CEO, in the\nform of a supplement to the subsection 43(2)"}], "rationale": "FSMA Part 9 establishes an *extraterritorial* SG licensing regime for digital token service providers (DTSPs): an SG-incorporated entity providing DT services *outside Singapore* must hold a DTSP licence. The AU AML/CTF Act 2006 is *territorial* but applies to designated services provided in Australia or to Australian residents. The two regimes therefore overlap when an SG-incorporated DTSP services Australian customers — both jurisdictions assert AML/CFT-style obligations on the same service flow. Unlike the structural non-transit conflicts (e.g. MiCA-vs-DAP), this overlap is *operationally resolvable*: the AU and SG AML frameworks are not contradictory — they impose parallel CDD, transaction-monitoring and reporting obligations that a well-designed compliance programme can satisfy simultaneously. The resolution is compliance-engineering: implement a single CDD pipeline that meets both the SG DTSP guidelines and the AUSTRAC-administered AML/CTF Rules (operational floor), and submit reports to both AUSTRAC and MAS. Severity is medium because the duplication is real (two licences, two supervisors, two reporting cadences) but not legally irreconcilable.", "compliant_paths": ["Operate a unified CDD policy that meets the higher floor of both regimes (typically AUSTRAC's prescriptive Rules) and report into each supervisor separately.", "Where possible, rely on AUSTRAC–MAS information-sharing arrangements to avoid double-reporting of suspicious-matter equivalents."], "out_of_scope_assumptions": ["SG entity is genuinely SG-incorporated and within FSMA's extraterritorial scope (not merely SG-marketed).", "AU customers receiving the service are AU residents — purely AU-tourist outbound transactions are out of scope."]}
{"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:7ee55831f76802c32ef2ad4e", "label": "non_conflict", "regime_a": {"regime_id": "EU_DORA", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "DORA"}, "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": "85307f9e2a040982::4cd::269e", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 30, "passage": "Article 6\nICT risk management framework\n1. Financial entities shall have a sound, comprehensive and well-documented ICT risk management framework as part\nof their overall risk management system, which enables them to address ICT risk quickly, efficiently and comprehensively\nand to ensure a high level of digital operational resilience.\n2. The ICT risk management framework shall include at least strategies, policies, procedures, ICT protocols and tools\nthat are necessary to duly and adequately protect all information assets and ICT assets, including computer software,\nhardware, servers, as well as to protect all relevant physical components and infrastructures, such as premises, data centres\nand sensitive designated areas, to ensure that all information assets and ICT assets are adequately protected from risks\nincluding damage and unauthorised access or usage.\n3. In accordance with their ICT risk management framework, financial entities shall minimise the impact of ICT risk by\ndeploying appropriate strategies, policies, procedures, ICT protocols and tools. They shall provide complete and updated\ninformation on ICT risk and on their ICT risk management framework to the competent authorities upon their request.\n4."}], "evidence_b": [{"chunk_id": "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": "DORA governs ICT risk management, operational resilience and third-party ICT risk for EU financial entities. FATF Recommendation 16 is an AML/CFT standard on wire/VA transfer originator and beneficiary information. The two cover disjoint subject matters; no plausible single-firm obligation under one contradicts an obligation under the other. Textbook easy negative.", "would_conflict_if": ["DORA's ICT operational requirements rendered FATF travel-rule data transmission technically infeasible — not the case; travel-rule transmission is an ordinary application-layer obligation."]}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:43add5c76188f04086d484c7", "label": "non_conflict", "regime_a": {"regime_id": "EU_PSD2", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_PSD2"}, "regime_b": {"regime_id": "SG_PSA_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_PSA_GENERAL"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "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": "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_PSD2 (Article 97 strong customer authentication for payment service providers in the EU) and SG_PSA_GENERAL (Singapore Payment Services Act regulations / safeguarding consultation). Both broadly regulate payment services but apply in non-overlapping jurisdictions and address different specific obligations (SCA vs safeguarding of customer assets). No obligation conflict on the cited evidence."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:28:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:13d4c17cb13be6d2fc0c83c4", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "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": "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": "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 evidence for the Australian regime (AU_ATO_CRYPTO) focuses on the taxation of crypto assets and general regulatory reform (chunk_id e6bb47e92e88e16c::567::36c4). The evidence for the European regime (EU_PSD2) focuses on payment service provider authentication and security standards for electronic payments (chunk_id adb1a81b9cecaf8c::64f::f5ad). The obligations and subject matter of the two regimes are distinct; one regulates tax compliance for crypto assets, while the other regulates security and authentication for payment services. There is no evidence of a specific obligation in one regime pushing against a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:06:15Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:1647b9a0b561dc8078b06864", "label": "non_conflict", "regime_a": {"regime_id": "AU_ASIC_AFSL", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ASIC_AFSL"}, "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": "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": "b49627bb889ef1d9::3ef::7168", "source_doc": "Guidelines_to_PSN02_2024-04-02.pdf", "page": 66, "passage": "19 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}, {"chunk_id": "d6f4be6b9d136778::467::12af", "source_doc": "Guidelines_to_MAS_Notice_PSN02_2025-07.pdf", "page": 69, "passage": "30 For instance, in 24 May 2018, MAS directed an ICO issuer to stop offering its digital tokens and to return all funds\nreceived from Singapore-based investors. MAS also warned eight digital token exchanges in Singapore not to facilitate\ntrading in digital tokens that are securities or futures contracts without MAS' authorisation\n(https://www.mas.gov.sg/news/media-releases/2018/mas-warns-digital-token-exchanges-and-ico-issuer). In January\n2019, MAS warned an ICO issuer not to proceed with its securities token offering in Singapore until it can comply with\nregulatory requirements (https://www.mas.gov.sg/news/media-releases/2019/mas-halts-securities-token-offering-for-\nregulatory-breach). monitoring the risks posed by these new business models, and will take the\nnecessary steps to mitigate the risks posed. III-1-3 In light of the enhanced FATF standards for virtual assets (issued in June 2019),\nMAS has announced its intention to expand the scope of legislation, including the\nPS Act, to cover additional activities of virtual assets by service providers so as to\nfully align with international AML/CFT requirements."}], "rationale": "The Australian regime (Regime A) focuses on the licensing requirements for financial services providers (AFSL) and specific obligations for platform providers, brokers, and intermediaries dealing in digital asset facilities within Australia. The Singaporean regime (Regime B) discusses MAS enforcement actions against ICO issuers and exchanges, and the intention to expand legislation to align with international AML/CFT standards. The passages describe distinct regulatory actions and enforcement contexts (MAS warnings vs. AFSL licensing obligations) rather than conflicting obligations. The Australian text outlines a specific exemption for 'low value facility' providers (chunk 550958b067dc6726::41f::546c), which is a design choice rather than a conflict with Singaporean law. Therefore, the regimes regulate different aspects of the digital asset ecosystem and do not impose conflicting obligations."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T19:18:14Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:9c020f8b5892969c1bbd0275", "label": "non_conflict", "regime_a": {"regime_id": "EU_MAR", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MAR"}, "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": "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": "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_MAR regime regulates market abuse, specifically insider dealing and market manipulation (chunk 5cc4a27bc578287a::4ee::5950). The SG_AML regime regulates money laundering and terrorism financing (chunk 3d521e61e49aaf46::38f::e615). The obligations in the EU_MAR passage relate to detecting and reporting suspicious orders and transactions that constitute market abuse, whereas the SG_AML passage requires officers and employees to be trained on AML/CFT laws and detecting suspicious transactions. These are distinct regulatory domains; the EU_MAR obligations do not impose a specific conflict with the SG_AML training requirements, nor do they overlap in a way that creates a structural or operational conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:51:04Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:68228d6aabaa744115788213", "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_AML_GENERAL", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "SG_MAS_AML_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "adb1a81b9cecaf8c::64f::f5ad", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 72, "passage": "Article 97\nAuthentication\n1. Member States shall ensure that a payment service provider applies strong customer authentication where the payer:\n(a) accesses its payment account online;\n(b) initiates an electronic payment transaction;\n(c) carries out any action through a remote channel which may imply a risk of payment fraud or other abuses.\n2. With regard to the initiation of electronic payment transactions as referred to in point (b) of paragraph 1, Member\nStates shall ensure that, for electronic remote payment transactions, payment service providers apply strong customer\nauthentication that includes elements which dynamically link the transaction to a specific amount and a specific payee.\n3. With regard to paragraph 1, Member States shall ensure that payment service providers have in place adequate\nsecurity measures to protect the confidentiality and integrity of payment service users' personalised security credentials.\n4. Paragraphs 2 and 3 shall also apply where payments are initiated through a payment initiation service provider.\nParagraphs 1 and 3 shall also apply when the information is requested through an account information service provider.\n5. Member States shall ensure that the account servicing payment service provider allows the payment initiation\nservice provider and the account information service provider to rely on the authentication procedures provided by\nthe account servicing payment service provider to the payment service user in accordance with paragraphs 1 and 3 and,\nwhere the payment initiation service provider is involved, in accordance with paragraphs 1, 2 and 3."}, {"chunk_id": "adb1a81b9cecaf8c::31a::3b3b", "source_doc": "PSD2_Directive_EU_2015-2366.pdf", "page": 23, "passage": "23.12.2015 EN Official Journal of the European Union L 337/59\n(30) 'strong customer authentication' means an authentication based on the use of two or more elements categorised as\nknowledge (something only the user knows), possession (something only the user possesses) and inherence\n(something the user is) that are independent, in that the breach of one does not compromise the reliability of\nthe others, and is designed in such a way as to protect the confidentiality of the authentication data;\n(31) 'personalised security credentials' means personalised features provided by the payment service provider to a\npayment service user for the purposes of authentication;\n(32) 'sensitive payment data' means data, including personalised security credentials which can be used to carry out fraud."}], "evidence_b": [{"chunk_id": "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_PSD2 passages focus on technical security standards for payment authentication (strong customer authentication, personalised security credentials) and governance requirements for payment institutions (Article 97, Article 98, Article 11). In contrast, the SG_MAS_AML_GENERAL passages discuss the regulatory framework for combating money laundering and terrorism financing, specifically targeting Digital Payment Token (DPT) providers and financial institutions. The SG passages reference 'AML/CFT compliance function,' 'targeted financial sanctions,' and 'robust licensing fit and proper checks,' which are distinct from the technical authentication obligations in EU_PSD2. The obligations in the EU regime do not push against the obligations in the SG regime; rather, they regulate different domains (payment security vs. financial crime prevention)."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.85, "record_type": "non_conflict", "pair_id": "non_conflict:290f15997c9c1db20fa1480f", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "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_RTS (EU technical standards for CASP authorisation under MiCA) and SG_PSA_DPT (MAS's PSN02 AML notice for DPT licensees under Singapore's PSA). Both apply to crypto-asset service providers but in non-overlapping jurisdictions; the cited passages address different specific obligations (CASP authorisation requirements vs PSN02 AML obligations)."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T15:30:43Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.95, "record_type": "non_conflict", "pair_id": "non_conflict:80e6036b32852c758bffb117", "label": "non_conflict", "regime_a": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "regime_b": {"regime_id": "SG_STABLECOIN", "jurisdiction": "Singapore", "issuing_body": "MAS-Consultations", "short_name": "SG_STABLECOIN"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}, {"chunk_id": "85240528438654b9::284::b4a8", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 38, "passage": "94. The FATF Standards, including the definitions of virtual assets and VASPs, represent\na minimum standard for countries to introduce. In line with the RBA, countries may\nchoose to extend their AML/CFT regimes to include other digital assets and entities,\nbeyond the FATF definition of virtual asset and VASP. Such a determination should\nbe made on the basis of a ML/TF risk assessment, with consideration of the\nchallenges associated with regulatory divergence.\n\nUPDATED GUIDANCE: A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS  37\nPART THREE:\nAPPLICATION OF FATF STANDARDS TO COUNTRIES AND\nCOMPETENT AUTHORITIES"}], "evidence_b": [{"chunk_id": "58f45cd2ef3de201::36c::e2f6", "source_doc": "2023_Response_Stablecoin_Consultation.pdf", "page": 3, "passage": "1 Consultation on the Payment Services Act 2019: Scope of E-money and Digital Payment Tokens, Dec 2019 here.\n\n2 Consultation on Proposed Regulatory Approach for Stablecoin-related Activities, Oct 2022 here.\n\n15 August 2023 | 4\n\n2. Overall Regulatory Approach for Stablecoins\nScope of MAS' stablecoin framework\n\n2.1. In the consultation paper, MAS proposed to bring within the stablecoin regulatory regime, single-\ncurrency stablecoins (\"SCS\") pegged to the Singapore dollar or Group of Ten (\"G10\") currencies3, that\nare issued in Singapore - herein known as the \"SCS framework\". Non-SCS will continue to be subject to\nthe existing DPT regulatory regime under the Payment Services Act 2019 (\"PS Act\"). MAS sought\ncomments on whether the regulatory scope was adequate and whether there might be reasons for\nMAS to extend its regulatory powers to SCS issued outside of Singapore."}, {"chunk_id": "33d059aa86716ddd::4ed::8511", "source_doc": "2022_CP_Stablecoin_Regulatory_Approach.pdf", "page": 6, "passage": "3.5 A wide range of stablecoins currently exist, varying in terms of their asset-\npegging, as well as the mechanism that upholds the stability of the stablecoins' value\nagainst the pegged asset(s). MAS intends to focus its regulatory regime on:\nSingle-currency pegged stablecoins (SCS) - As compared to other types of\nstablecoins (such as those pegged to a basket of currencies or other\nassets such as commodities), SCS has a stronger use case for payment and\nsettlement.\nNon-SCS will continue to be subject to the existing DPT regime under the\nPS Act. MAS views such stablecoins as being less stable in nominal value\nand should be treated differently from SCS.\nIn addition, even among SCS, there is variation in the stabilisation\nmechanism. MAS views stablecoins which are algorithmically-pegged,\nunbacked or backed by other cryptocurrencies to be more susceptible to\nvolatility in value. Correspondingly, such stablecoins will also continue to\nbe treated as DPTs.\nSCS issued in Singapore - The immediate priority of MAS is to elevate the\nstandard of SCS issued in Singapore. Our regulatory perimeter is thus\nscoped based on MAS' ability to directly impose requirements on the\nreserve management, redemption policies and prudential standards of\nthe SCS issuer."}], "rationale": "The FATF VASP regime (Regime A) establishes a global minimum standard for Virtual Asset Service Providers (VASPs) and Virtual Assets (VAs), emphasizing a risk-based approach and technology neutrality. The Singapore Stablecoin regime (Regime B) focuses specifically on regulating Single-Currency Stablecoins (SCS) issued in Singapore under the Payment Services Act. The passages show that Regime B applies a specific, narrower regulatory perimeter to SCS (chunk_id 58f45cd2ef3de201::36c::e2f6, chunk_id 33d059aa86716ddd::4ed::8511) while noting that non-SCS remain under the Digital Payment Token (DPT) regime. Regime A allows countries to extend their AML/CFT obligations beyond the minimum FATF definition of VASP (chunk_id 85240528438654b9::284::b4a8) and permits countries to not impose a separate licensing system for entities already licensed as financial institutions performing VASP activities (chunk_id ba862e1f095bceac::1a6::1f0e). The regimes are aligned in their intent to regulate digital assets and service providers, but Regime B's specific focus on SCS and its application within the existing PS Act framework does not create a structural conflict with the FATF's general VASP standards. Instead, the Singapore regime appears to be implementing the FATF standards within its specific stablecoin context."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:17:02Z", "revision": 1, "review_status": "single_annotation", "confidence": 1.0, "record_type": "non_conflict", "pair_id": "non_conflict:5b68617074e68e8691885465", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_TITLE_V_CASP", "jurisdiction": "EU", "issuing_body": "EUR-Lex", "short_name": "EU_MICA_TITLE_V_CASP"}, "regime_b": {"regime_id": "INT_BASEL_GENERAL", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_BASEL_GENERAL"}, "non_conflict_subtype": "different_domains", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::147::6214", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 8, "passage": "17. Article 62 of MiCA provides for the requirements for the application for authorisation as\nCASP. More particularly, Article 62(1) of MiCA obliges legal persons or other\nundertakings that intend to provide crypto-asset services to submit their application for\nan authorisation as a CASP to the NCA of their home Member State."}, {"chunk_id": "c51ad46265cea4e5::34a::74e3", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 11, "passage": "33. Article 109(1)(d) MiCA requires ESMA to establish a register of CASPs which must be\npublicly available on its website and be updated on a regular basis. Article 109(5) MiCA\nspecifies the information which the register must contain, including the name, legal form\nand legal entity identifier of the CASP and, where applicable, of the where applicable, of\nthe CASP's branches and the list of crypto-asset services provided by the CASP. To\nensure that an application for authorisation also contains all information required for the\nfuture ESMA public register of CASPs, ESMA proposes to include a few additional\ninformation requirements of limited extent to reflect the requirements of Article 109(5) of\nMiCA in the draft RTS on the application for authorisation as a CASP.\n\n4 Complaints-handling procedures of crypto-asset service\nproviders"}], "evidence_b": [{"chunk_id": "32afd37cade34f84::34b::8d30", "source_doc": "d424.pdf", "page": 148, "passage": "11 Where a bank according to its operative accounting framework recognises fiduciary assets on the balance sheet, these assets\ncan be excluded from the leverage ratio exposure measure provided that the assets meet the IFRS 9 criteria for derecognition\nand, where applicable, IFRS 10 for deconsolidation.\n\n12 Although paragraph 60 of the Basel III framework specifies the treatment of general provisions/general loan-loss reserves for\nbanks using the standardised approach for credit risk, for the purposes of the leverage ratio exposure measure the definition\nof general provisions/general loan-loss reserves specified in paragraph 60 of the Basel III framework applies to all banks\nregardless of whether they use the standardised approach or the internal ratings-based (IRB) approach for credit risk for their\nrisk-based capital calculations."}, {"chunk_id": "32afd37cade34f84::34e::4d5c", "source_doc": "d424.pdf", "page": 84, "passage": "141. Section G discusses the method by which the difference between provisions (eg specific\nprovisions, portfolio-specific general provisions such as country risk provisions or general provisions) and\nexpected losses may be included in or must be deducted from regulatory capital, as outlined in the\ndefinition of capital section of the Basel III framework (June 2011).\n\n1. Calculation of expected losses\n\n142. A bank must sum the EL amount (defined as EL multiplied by EAD) associated with its exposures\nto which the IRB approach is applied (excluding the EL amount associated with securitisation exposures)\nto obtain a total EL amount. The treatment of EL for securitisation exposures is described in paragraph 37\nof the securitisation framework.\n(i) Expected loss for exposures other than exposures subject to the supervisory slotting\ncriteria"}], "rationale": "The EU MiCA passages (c51ad46265cea4e5::147::6214, c51ad46265cea4e5::34a::74e3) regulate the authorisation, information requirements, and public register obligations for Crypto-Asset Service Providers (CASPs). The Basel III passages (32afd37cade34f84::34b::8d30, 32afd37cade34f84::34e::4d5c) regulate banking sector capital adequacy, leverage ratios, and the treatment of provisions and expected losses. The obligations in MiCA regarding CASP licensing and reporting do not overlap with the Basel III framework's banking capital and risk management requirements. Therefore, the regimes are in different domains and do not conflict."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T05:30:10Z", "revision": 1, "review_status": "reviewed_accept", "confidence": 0.75, "record_type": "conflict", "pair_id": "conflict:35e62316d9d45f1c480a1e86", "label": "conflict", "regime_a": {"regime_id": "EU_EMD2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_EMD2"}, "regime_b": {"regime_id": "SG_PSA_DPT", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_PSA_DPT"}, "conflict_type": "structural_unresolved", "severity": "medium", "evidence_a": [{"chunk_id": "85307f9e2a040982::14a::134d", "source_doc": "DORA_Regulation_EU_2022-2554.pdf", "page": 22, "passage": "(27) Directive (EU) 2022/2556 of the European Parliament and of the Council of 14 December 2022 amending Directives 2009/65/EC,\n2009/138/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU, 2014/65/EU, (EU) 2015/2366 and (EU) 2016/2341 as regards digital\noperational resilience for the financial sector (see page 153 of this Official Journal)."}], "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_EMD2 (EU E-Money Directive 2 — EMI authorisation for issuance/redemption of e-money) and SG_PSA_DPT (SG Payment Services Act DPT-service licensing). Both regulate issuer/service-provider licensing for similar payment instruments but in non-transitable jurisdictional frameworks. An EU EMI cannot issue under SG's PSA framework without separate authorisation. Same non-transit pattern. Severity medium because the instruments (e-money vs DPT) are not directly equivalent; the structural conflict is narrower than CASP-vs-CASP.", "review": {"reviewer_id": "10116", "reviewed_at": "2026-06-18T13:27:00Z", "decision": "accept", "notes": "", "original_conflict_type": "structural_unresolved", "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": 0.92, "record_type": "non_conflict", "pair_id": "non_conflict:5fb073569165c389a0f33827", "label": "non_conflict", "regime_a": {"regime_id": "AU_AML_CTF", "jurisdiction": "Australia", "issuing_body": "AUSTRAC", "short_name": "AU_AML_CTF"}, "regime_b": {"regime_id": "INT_FATF_VASP", "jurisdiction": "International", "issuing_body": "?", "short_name": "INT_FATF_VASP"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "254ca2d92d196180::2ac::a5fe", "source_doc": "AML_CTF_Act_2006.pdf", "page": 119, "passage": "Part 3-Reporting obligations\nDivision 1-Introduction\n40 Simplified outline\nThe following is a simplified outline of this Part:\n• A reporting entity must give the AUSTRAC CEO reports\nabout suspicious matters.\n• If a reporting entity provides a designated service that\ninvolves a threshold transaction, the reporting entity must give\nthe AUSTRAC CEO a report about the transaction.\n• If a person sends or receives an international funds transfer\ninstruction, the person must give the AUSTRAC CEO a report\nabout the instruction.\n• A reporting entity may be required to give AML/CTF\ncompliance reports to the AUSTRAC CEO.\nAnti-Money Laundering and Counter-Terrorism Financing Act 2006 101"}], "evidence_b": [{"chunk_id": "85240528438654b9::1cd::07d7", "source_doc": "Updated-Guidance-VA-VASP.pdf.coredownload.inline.pdf", "page": 24, "passage": "45. The purpose of adding the new definitions of VA and VASP to the FATF Glossary was\nto broaden the applicability of the FATF Standards to encompass new types of\ndigital assets and providers of certain services in those assets. It was not intended\nto subtract from the existing definitions of \"funds\", \"funds or other assets\", or from\nthe scope of the various financial services included under the definition of a\n\"financial institution\" in the FATF Standards."}], "rationale": "AU_AML_CTF (Australian AML/CTF Act — AUSTRAC reporting framework) and INT_FATF_VASP (FATF VASP guidance — AML/CFT standards for VAs and VASPs). Australia's AML/CTF Act applies FATF-aligned obligations on digital-currency exchanges (VASP equivalent). Reinforcing."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:16:19Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:eb2b88dde45831b7a44ec666", "label": "non_conflict", "regime_a": {"regime_id": "AU_ATO_CRYPTO", "jurisdiction": "Australia", "issuing_body": "?", "short_name": "AU_ATO_CRYPTO"}, "regime_b": {"regime_id": "MAS_TRM", "jurisdiction": "Singapore", "issuing_body": "?", "short_name": "MAS_TRM"}, "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": "20d526d712753652::403::be97", "source_doc": "2025_Response_to_DTSP_CP.pdf", "page": null, "passage": "Licensees should also establish internal processes to determine the impact of the\ninaccuracies on its customers to determine whether additional actions should be taken. For\nexample, licensees may wish to inform customers of the inaccuracy. MAS does not intend to propose\nadditional requirements in FSM-N33 Notice relating to inaccurate representations regarding the\nscope of a licensee's regulation by MAS at this juncture. 30 May 2025 | 21\n8. Guidelines applicable to licensees\n8.1. MAS proposed for guidelines that apply to all financial institutions to also be applied to all licensees. This includes the Guidelines on Fit and Proper Criteria (\"F&P Guidelines\"), TRM Guidelines,\nGuidelines on Business Continuity Management and Guidelines on Outsourcing.\n8.2. Respondents are generally supportive of the application of the aforementioned guidelines on\nlicensees.\n8.3. Several respondents suggested to expand the cybersecurity component within the TRM Guidelines\nto include specific risks associated with digital tokens.\n8.4."}], "rationale": "The evidence from the AU_ATO_CRYPTO regime focuses on the Australian Taxation Office's (ATO) approach to token mapping, tax compliance, and the regulation of crypto assets within Australia (chunk_id e6bb47e92e88e16c::567::36c4). The evidence from the MAS_TRM regime focuses on the Monetary Authority of Singapore's (MAS) response to feedback regarding guidelines for licensees, including the application of Fit and Proper Criteria and Business Continuity Management (chunk_id 20d526d712753652::403::be97). The two regimes regulate distinct geographic jurisdictions (Australia vs. Singapore) and address different regulatory domains (taxation vs. financial services licensing and conduct). There is no evidence of a specific obligation in one regime conflicting with a specific obligation in the other."}
{"annotator_id": 10116, "annotated_at": "2026-06-15T16:10:31Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.9, "record_type": "non_conflict", "pair_id": "non_conflict:7743e525b9414fa9909c229a", "label": "non_conflict", "regime_a": {"regime_id": "EU_NIS2", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_NIS2"}, "regime_b": {"regime_id": "SG_PDPA", "jurisdiction": "Singapore", "issuing_body": "SSO", "short_name": "SG_PDPA"}, "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": "0e996ae99839f19e::37b::85a8", "source_doc": "Personal_Data_Protection_Act_2012.pdf", "page": 20, "passage": "PART 4\nCOLLECTION, USE AND DISCLOSURE OF\nPERSONAL DATA\nDivision 1 - Consent\nConsent required\n13. Anorganisationmustnot,onorafter2July2014,collect,useor\ndisclose personal data about an individual unless -\n(a) the individual gives, or is deemed to have given, his or her\nconsent under this Act to the collection, use or disclosure,\nas the case may be; or\n(b) the collection, use or disclosure (as the case may be)\nwithout the individual's consent is required or authorised\nunder this Act or any other written law. Provision of consent\n14.-(1) An individual has not given consent under this Act for the\ncollection, use or disclosure of personal data about the individual by\nan organisation for a purpose unless -\n(a) the individual has been provided with the information\nrequired under section 20; and\n(b) the individual provided his or her consent for that purpose\nin accordance with this Act."}], "rationale": "The EU_NIS2 passage discusses the preparation of technical standards and guidelines for access control policies and cryptography (chunk_id 3c9eb3a25c93f394::474::4786). The SG_PDPA passage outlines the requirements for consent in the collection, use, and disclosure of personal data (chunk_id 0e996ae99839f19e::37b::85a8). The obligations in NIS2 relate to ICT security measures, while the obligations in the PDPA relate to data protection and consent. These are distinct regulatory domains; there is no specific obligation in NIS2 that pushes against a specific obligation in the PDPA."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:17:34Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:c6a363938bf30a4e8f160bc4", "label": "non_conflict", "regime_a": {"regime_id": "EU_MICA_RTS", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_MICA_RTS"}, "regime_b": {"regime_id": "SG_FSMA_DTSP", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_FSMA_DTSP"}, "non_conflict_subtype": "superficially_similar_but_disjoint", "evidence_a": [{"chunk_id": "c51ad46265cea4e5::2f5::4513", "source_doc": "FinalReport_Technical_Standards_MiCA_1st_Package.pdf", "page": 25, "passage": "6.1.2 RTS and ITS on the notification by certain financial entities to\nprovide crypto-asset services\nImpact of the draft RTS and ITS under Article 60(13) and (14) of MiCA\n\n21. As per Article 10(1) of Regulation (EU) No 1095/2010, any draft regulatory technical\nstandards and implementing technical standards developed by ESMA shall be\naccompanied by an analysis of 'the potential related costs and benefits' of the technical\nstandards.\n\n22. MiCA sets out a new legal framework applicable to certain financial entities intending to\nprovide crypto-asset services, requiring such entities to notify all the information set out\nin Article 60(7) of MiCA, as specified by the RTS on the notification by certain financial\nentities to provide crypto-asset services."}], "evidence_b": [{"chunk_id": "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": "EU_MICA_RTS (technical standards for CASP authorisation/notification under MiCA) and SG_FSMA_DTSP (Singapore's DTSP licensing under the FSM Act) both regulate crypto-asset service providers but in non-overlapping jurisdictions. The MiCA RTS apply to EU CASPs; the SG DTSP framework to SG-licensed digital token service providers. Different jurisdictional perimeters; no obligation conflict on cited passages."}
{"annotator_id": 10116, "annotated_at": "2026-06-16T04:29:32Z", "revision": 1, "review_status": "single_annotation", "confidence": 0.88, "record_type": "non_conflict", "pair_id": "non_conflict:579e69e418c4525975269a30", "label": "non_conflict", "regime_a": {"regime_id": "EU_AMLA", "jurisdiction": "EU", "issuing_body": "?", "short_name": "EU_AMLA"}, "regime_b": {"regime_id": "SG_AML", "jurisdiction": "Singapore", "issuing_body": "MAS-Guidelines", "short_name": "SG_AML"}, "non_conflict_subtype": "aligned_complementary", "evidence_a": [{"chunk_id": "df546f2364aaf9e2::15a::fbf2", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 80, "passage": "Article 63\nCooperation with AMLA\nFIU and supervisory authorities shall cooperate with AMLA and shall provide it with all the information necessary to allow\nit to carry out its duties under this Directive and under Regulations (EU) 2024/1624 and (EU) 2024/1620.\nSECTION 2\nCooperation with other authorities and exchange of confidential information"}, {"chunk_id": "df546f2364aaf9e2::620::328c", "source_doc": "AMLD6_Directive_EU_2024-1640.pdf", "page": 79, "passage": "Article 62\nCommunication of the list of the competent authorities\n1. In order to facilitate and promote effective cooperation, and in particular the exchange of information, Member States\nshall communicate to the Commission and AMLA:\n(a) the list of supervisors responsible for overseeing the compliance of the obliged entities with Regulation (EU)\n2024/1624, as well as, where relevant, name of the public authority overseeing self-regulatory bodies in their\nperformance of supervisory functions under this Directive, and their contact details;\n(b) the contact details of their FIU;\n(c) the list of other competent national authorities.\n2. For the purposes of paragraph 1, the following contact details shall be provided:\n(a) a contact point or, failing that, the name and role of a contact person;\n(b) the email and phone number of the contact point or, failing that, the professional email address and phone number of\nthe contact person.\nELI: http://data.europa.eu/eli/dir/2024/1640/oj 79/94\n\nEN\n3. Member States shall ensure that the information provided to the Commission and AMLA pursuant to paragraph 1 is\nupdated as soon as a change takes place.\n4. AMLA shall publish a register of the authorities referred to in paragraph 1 on its website and facilitate the exchange of\ninformation referred to in paragraph 2 between competent authorities. The authorities in the register shall, within the scope\nof their powers, serve as a contact point for the counterpart competent authorities. FIUs and supervisory authorities shall\nalso serve as a contact point for AMLA."}], "evidence_b": [{"chunk_id": "3d521e61e49aaf46::38f::e615", "source_doc": "MAS_Notice_314_LifeInsurers_2021-06-28.pdf", "page": 27, "passage": "13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees\nand agents (whether in Singapore or elsewhere) are regularly and appropriately trained\non -\n(a) AML/CFT laws and regulations, and in particular, CDD measures, detecting and\nreporting of suspicious transactions;\n(b) prevailing techniques, methods and trends in money laundering and terrorism\nfinancing; and\n(c) the direct life insurer's internal policies, procedures and controls on AML/CFT and\nthe roles and responsibilities of officers, employees and agents in combating\nmoney laundering and terrorism financing. Endnotes on History of Amendments\n1. MAS Notice 314 dated 2 July 2007. (a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2\nDecember 2009. (b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013. (c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.\n2."}, {"chunk_id": "39886a6842407c92::356::ee53", "source_doc": "MAS_Notice_626_Banks_2025-06-30.pdf", "page": 6, "passage": "3.1 This Notice is based on the following principles, which shall serve as a guide for all banks\nin the conduct of their operations and business activities:\n(a) A bank shall exercise due diligence when dealing with customers, natural persons\nappointed to act on the customer's behalf, connected parties of the customer and\nbeneficial owners of the customer.\n(b) A bank shall conduct its business in conformity with high ethical standards, and\nguard against establishing any business relations or undertaking any transaction,\nincluding a digital token transaction, that is or may be connected with, or facilitates\nor may facilitate money laundering or terrorism financing.\n(c) A bank shall, to the fullest extent possible, assist and cooperate with the relevant\nlaw enforcement authorities in Singapore to prevent money laundering and\nterrorism financing."}], "rationale": "EU_AMLA (EU's new Anti-Money Laundering Authority under AMLD6 — supervisory cooperation framework) and SG_AML (MAS Notice 314 + MAS Notice 626 AML/CFT frameworks for life insurers and banks). Both implement AML/CFT supervisory architecture in their respective jurisdictions consistent with FATF standards. Reinforcing rather than conflicting."}