Stockholm

The Stockholm DARTE session took place on May 25th, 2026, at the Estonian House (Estniska Huset), in collaboration with the European Commission and the Nordic Blockchain Association. This edition brought together regulators, legal practitioners, and digital asset infrastructure providers to examine three pressing questions at the intersection of AML compliance, market integrity, and the regulatory perimeter of novel on-chain instruments.
The roundtable explored three interconnected themes.

The session opened with welcome notes by Magnus Jones (Nordic Blockchain Association) and Kadri Roosimägi (Estonian Embassy in Stockholm), followed by an introduction to the DARTE concept. Uve Poom (CryptoSwift) then examined the Travel Rule's operational gaps as cryptocurrency transfers expand into real-world payments, making the case for external KYC of third-party counterparties, a whitelist of DORA-compliant Travel Rule service providers, and the extension of the Travel Rule data standard to support meaningful AML, enhanced due diligence, and B2B payment use cases. Karola Xenia Kassai (KassaiLaw) followed with an analysis of the structural ambiguity in MiCAR's market abuse regime, exploring when blockchain-derived information becomes inside information in markets that are transparent but asymmetrically interpretable. Dr. Nina-Luisa Siedler (siedler legal and DAAvern) closed the technical sessions with a discussion of prediction markets and MiCAR market abuse rules, addressing the regulatory grey zone in which prediction-market positions sit between MiCAR, MAR, and national wagering law, and the conduct-based supervisory response this calls for. The session concluded with closing remarks by Dr. Nina-Luisa Siedler.

The Stockholm edition reinforced DARTE's role as a venue for grounded, multi-stakeholder dialogue on the operational realities of digital asset regulation, underscoring that as crypto-assets enter new use cases, from real-world payments to event-linked markets, the regulatory frameworks designed for earlier phases of the industry will need both interpretive clarification and a more conduct-focused supervisory approach to remain effective.

Full Report

Travel Rule – Third Party KYC and Enhanced Due Diligence

The first session examined the structural weaknesses of the Travel Rule architecture as cryptocurrency transfers expand from exchange deposits and withdrawals into real-world payments. Participants discussed the absence of meaningful counterparty verification for transactions involving third parties, the ineffectual prohibition on transfers above €1,000 to third-party self-hosted wallets, the DORA and data sovereignty risks created by reliance on non-EU Travel Rule providers, and the operational gaps in the Travel Rule data standard itself, including the absence of fields needed for conclusive AML and EDD checks and the lack of a payment explanation field essential for B2B use cases.

When Does Blockchain Data Become Inside Information?

The second session addressed a structural ambiguity in MiCAR's market abuse regime: how the framework's traditional financial markets concepts apply in blockchain markets where transparency is universal but analytical access is highly asymmetrical. Participants discussed whether information that is technically public on-chain but realistically interpretable only by sophisticated actors should still be considered non-public under Article 87, the layered structure of informational access across CASPs, validators, analytics firms, and retail participants, and the practical case for a more conduct-based supervisory approach focused on identifiable abusive patterns rather than exhaustive classification of every form of blockchain-derived information.

Prediction Markets and MiCAR Market Abuse Rules

The third session addressed the regulatory grey zone in which blockchain-based prediction markets sit between MiCAR, MAR, and national wagering law. Drawing on recent reporting of alleged insider-style activity on Polymarket, participants discussed how prediction-market positions can satisfy MiCAR's crypto-asset definition while also potentially qualifying as MiFID II derivative contracts, and the risk that under either classification the substantive market abuse vocabulary may fail to address the underlying economic harm: unfair informational advantage, distorted prices, and a loss of market trust.

Call to Actions

Recognize external KYC as a basis for lifting the €1,000 SHW restriction, allowing CASPs to verify third-party counterparties via eID, remote ID verification, or digital identity wallet checks, and replacing an ineffectual blanket prohibition with a proportionate, evidence-based control.
Establish a whitelist of DORA-compliant Travel Rule service providers maintained at industry or regulatory level, bringing transparency to compliance posture, supporting interoperability, and reducing exposure to non-EU data access risks.
Extend the Travel Rule standard to include beneficiary identification fields necessary for conclusive AML and EDD checks and a payment explanation field for B2B use cases, designed with explicit data minimisation and privacy safeguards.

Call to Actions

Clarify the boundary of "public" information for blockchain-derived data, recognizing that a default treatment of on-chain data as inherently public is the more defensible starting point absent clear evidence of structurally inaccessible analytical capacity.
Embed conduct-based supervisory focus and operational safeguards within CASPs, including tiered internal information barriers, restricted trading and cooling-off periods for personnel with privileged visibility, and enhanced internal surveillance proportionate to the firm's informational position.
Account for the layered structure of informational access in the crypto ecosystem when designing market abuse obligations, calibrating expectations to the actual informational advantage held by each actor rather than treating all participants as informationally equivalent.

Call to Actions

Clarify the regulatory classification of prediction-market positions across MiCAR, MiFID II, and national wagering law, ensuring classification follows the economic substance of the position rather than the label applied by the platform.
Apply MAR and MiCAR market abuse provisions to prediction markets within their respective perimeters, so that conduct based on non-public, price-relevant event information is not treated as legally permissible simply because the venue is marketed as a prediction market.
Adopt a conduct-based supervisory approach to abusive activity in event-linked markets, focusing on identifiable patterns such as trading on non-public information about outcome-affecting events, regardless of the formal classification of the instrument.