Jan Struckmann
Jan is a Principal Associate in Freshfields' Frankfurt financial services regulatory group where his practice covers a wide range of financial services and regulatory matters, litigation and contentious proceedings as well as M&A in the financial sector.
Jan advises retail banks, investment banks, private wealth advisers, payment service providers and various non-regulated industry groups. His recent work has included advising clients on the impact of the new CRR3/CRD6 banking package (especially in a cross-border context), advising on various acquisitions and corporate restructurings in the financial services sector and advising an international payment services provider in litigation before German courts.
Jan has spent time on secondment at Goldman Sachs in Frankfurt and regularly contributes to legal journals, blogposts, client briefings and other publications.
1 Contributions by Jan Struckmann
PRACTICE NOTES
EU Recast WTR2 Cryptoasset Transfers: CASP Travel Rule obligations, scope and compliance, including self‑hosted addresses, messaging solutions and EBA Guidelines (applicable from 30 December 2024)
This Practice Note outlines the obligations of cryptoasset service providers (CASPs) under the EU’s Recast Wire Transfer Regulation 2 (Recast EU WTR2), also known as the Recast Funds Transfer Regulation 2 (Recast EU FTR2), together with the European Banking Authority’s (EBA) Travel Rule Guidelines, effective from 30 December 2024. It delivers practical direction on addressing core hurdles for CASPs, including self-hosted addresses and the absence of a standardised messaging framework.
Background
On 20 July 2021, the Commission unveiled an ambitious set of legislative proposals to reinforce the EU’s anti-money laundering (AML) and countering the financing of terrorism (CTF) regime. The objective of this AML package was to enhance the detection of suspicious transactions and activities, and to seal gaps exploited by criminals to launder illicit proceeds or fund terrorist activities through the financial system. The AML package comprises:
Regulation (EU) 2024/1624 on preventing the use of the financial system for the purposes of money laundering (ML) or terrorist financing (TF) (the AML Regulation, AMLR)
Directive (EU) 2024/1640 on the mechanisms to be established by Member States for the prevention of the use of the financial system for the purposes of ML/TF (6th Money Laundering
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EU Law
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