The EBA has published an opinion welcoming the European Commission's proposal to bring virtual currency exchange platforms and custodian wallet providers within the scope of the Fourth Money Laundering Directive ((EU) 2015/849) (MLD4), stating its belief that this will help mitigate risks of money laundering and terrorist financing that arise from the use of virtual currencies.  The EBA makes a number of recommendations, including: (i) the need for consistent implementation,; (ii)the retention of national sanctions; (iii) keeping transactions in virtual currencies should outside of the scope of the Payment Services Directive; (iv) clarifying the regulatory status and permitted activities of virtual exchange platforms and custodian wallet providers, including whether these entities should be allowed to carry out other regulated financial activities at the same time as carrying out virtual currency transactions; (v) clarifying how competent authorities should carry out fit and proper tests; and (vii) clarifying the details and scope of the proposed licensing or registration regime.