AI Act Compliance

AI Act Compliance Tailored for Crypto, Fintech & Web3

From crypto startups to global fintechs — Artlex makes your project bankable, investable, and regulator-ready: MiCA licensed, AI Act ready, and CE compliant.

AI Act readiness: your passport to the EU market

The EU Artificial Intelligence Act (AI Act) is already in force since August 2024.
For crypto and fintech companies, this is not a distant regulation — it directly affects how you use AI in AML/KYC, transaction monitoring, fraud detection, risk scoring, sanctions screening, or credit assessment.

Starting from February 2025, AI systems with unacceptable risks are banned. By August 2026, all AI systems used in compliance-critical functions (AML/KYC, fraud, scoring) will be classified as high-risk — triggering strict obligations: CE conformity assessment, EU database registration, risk governance, human oversight, and ongoing monitoring. Full enforcement will apply from August 2027, with additional rules for legacy systems in 2030.

For crypto platforms and fintech projects, this means one thing: compliance is no longer optional. Non-compliance can result in regulatory fines, frozen partnerships, blocked banking access, and halted expansion into the EU market.

Which Organizations Are Affected by the AI Act?

The AI Act applies broadly to all operators in the AI lifecycle — not only developers, but also companies that use AI. In the crypto and fintech sector, this includes:

Crypto exchanges and broker platforms (CASPs under MiCA)

if they use AI for KYC onboarding, AML monitoring, or fraud detection.

Fintech payment institutions and e-money providers

if they deploy AI for transaction monitoring, sanctions screening, or customer risk scoring.

Crypto custodians and wallet providers

when AI models are used to detect suspicious transfers or prevent fraud.

Blockchain analytics providers

offering AI-driven monitoring of transactions, wallet clustering, or illicit flow detection.

Third-party compliance & regtech providers (e.g., Sumsub, Elliptic)

as AI system providers, they must ensure CE conformity and system-level compliance.

Corporate users of AI tools (banks, VASPs/CASPs, neobanks, Web3 platforms)

as AI users, they must ensure oversight, governance, and responsible deployment.

Providers must make the AI compliant by design. Users must make sure the AI is used responsibly and auditable. This means crypto and fintech platforms cannot simply rely on vendor compliance — they must implement their own AI governance layer to stay regulator-ready.

Your Obligations under the AI Act

If you are an AI Provider:

You must ensure the AI system itself complies with the AI Act before it can be placed on the EU market:

▫CE conformity assessment and certification.

▫Registration in the EU High-Risk AI Database.

▫Comprehensive technical documentation (training data, risk management, testing).

▫Transparency & explainability measures built into the product.

▫ Post-market monitoring (reporting incidents, updating models, handling complaints).

 

 If you are an AI User:

You are responsible for how AI is applied inside your business:

▫Deploy AI only in line with provider’s instructions and safeguards.

▫Human oversight — decisions with legal or financial impact cannot be fully automated.

▫Maintain records & logs of AI-based decisions (e.g., onboarding rejections, flagged transactions).

▫Conduct risk assessments and governance checks before and during use.

▫Report serious incidents and risks to regulators.

▫Ensure customers’ rights (to explanation, contesting decisions, and human review). 

Why Artlex?

Niche expertise

 focus on crypto, fintech, and AI compliance, not generic legal.

Integrated view

 MiCA, AML/CTF, GDPR, and AI Act in one framework.

Independent compliance opinions & reports

 formal deliverables (opinion letters, gap analysis reports, regulator-ready documentation) that banks, investors, and partners recognize as a mark of credibility.

Our services

AI Act Gap Analysis

Structured review of how your platform uses AI in AML/KYC, fraud detection, transaction monitoring, or risk scoring.

▫Mapping of AI use cases.

▫Identification of compliance gaps.

▫Prioritized action roadmap.

Deliverable:

Gap Analysis Report with tailored recommendations. It is usable for internal compliance, regulator communication, and investor due diligence.

AI Governance & Policies

Practical documentation and frameworks required under the AI Act.

Our work covers:

▫Risk management framework tailored to crypto/fintech use cases.

▫Human oversight procedures (“human-in-the-loop”).

▫Policy templates & record-keeping tools ready for audits.

Deliverable:

Governance policy pack + compliance manual aligned with AI Act, MiCA, and AML laws.

CE Conformity Support

For developers of AI tools (e.g., KYC, fraud detection, blockchain analytics).

▫Compliance documentation preparation (risk management policies, governance framework, conformity declaration).

▫Coordination of technical input for collecting and structuring documentation from your AI/IT team.

▫Registration in the EU high-risk AI database.

▫Support with conformity assessment bodies during audits or certification.

Deliverable:

CE conformity package enabling lawful EU market deployment.

Independent Compliance Opinions

Formal documents that enhance trust with regulators, partners, and investors.

▫Regulatory Opinion Letters – confirming that your use of AI in AML/KYC, fraud detection, or transaction monitoring can be considered “AI Act Ready.”

▫Compliance Due Diligence Reports for banking onboarding, VC/fundraising, or licensing applications.

▫Integrated Compliance Reviews – mapping and aligning obligations under MiCA, GDPR, AML/CTF, and the AI Act, with practical gap analysis and prioritized next steps.

▫Readiness Statements – short formal documents that can be shared with partners, banks, and investors as a quality mark of compliance.

Deliverables: 

Independent compliance reports, letters, opinions and readiness statements, recognized in regulatory due diligence and onboarding processes.

Ongoing Monitoring & Updates

Stay ahead of regulatory change.

▫Regular monitoring of EU AI Act guidance and delegated acts.

▫Updates to your AML/KYC and AI policies.

▫Advisory on regulator expectations and enforcement trends.
Deliverable:

Compliance Monitoring Reports and update calls.

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