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Mag. Sanijel Ficulovic

Attorney at law

Sanijel is attorney in the Banking & Finance team at PFR Attorneys at law. He is specialised in banking, e-money and payment services law. His advisory focus lies in the regulatory assessment of new business models, the implementation of regulatory requirements and AML/CFT compliance. In addition, he regularly supports credit and financial institutions in investigation proceedings and the defence against administrative penalties. He also specialises in digital law and advising crypto asset service providers.

Practice areas

Curriculum
  • PFR Attorneys at Law (since 2018)
  • Bar exam (2022)
  • Fellner Wratzfeld & Partner Attorneys at Law (2016 to 2018)
  • Law studies, Universities of Vienna (2010 to 2016)
Languages
German, English, French, Serbian, Romanian

Contact

Phone +43 1 877 04 54
Mail This email address is being protected from spambots. You need JavaScript enabled to view it.

Latest publications

Legal commentary regarding Art 73 to 85 MiCAR
Legal commentary regarding Art 73 to 85 MiCAR

Art 73 to 85 in Raschauer/Ficulovic/Knobl/Kreisl/Pfurtscheller/Pracht/Silbernagl/Stern/Wessely/Wolfbauer, Kommentar zu MiCAR – Märkte in Kryptowerte (2024)

Handbook Payment Traffic 4.0
Handbook Payment Traffic 4.0

Freedom to provide services and freedom of establishment for payment institutions, in Tuder (Hrsg), Handbuch Zahlungsverkehr 4.0 / FinTechs – Krypto-Assets – Sandbox & Co. (2024)

ECJ on the enhanced due diligence obligations under the FM-GwG
ECJ on the enhanced due diligence obligations under the FM-GwG

ECJ on enhanced due diligence obligations under the FM-GwG and what Nord Stream 2 and KYCC have in common (together with Bernd Fletzberger), ZFR 2023/53, 113

ECJ rulings on the Money Laundering Directive
ECJ rulings on the Money Laundering Directive

ECJ rulings on the Money Laundering Directive (together with Bernd Fletzberger), FACTS 1/2023, 16

Latest news from

Mag. Sanijel Ficulovic

Interplay between MiCAR and PSD2: Update on the EBA No-Action Letter

18 February 2026
The beginning of March 2026 marks the end of an important transition period for crypto asset service providers (CASPs) that provi…
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Stablecoins and the Interplay between MiCAR, EMD2, and PSD2 – EBA No-Action Letter

15 December 2025
On June 10, 2025, the European Banking Authority (EBA) published a No-Action letter (EBA/Op/2025/08) on the interplay between Reg…
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Open Finance – a framework for financial data access (FIDA)

28 May 2025
On 28 June 2023, the European Commission published the draft regulation on Financial Data Access (FIDA or FIDAR) as part of the E…
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FATF Audit Adjustment Act 2024 and FM-GwG Adjustment Act – what is changing?

17 February 2025
Two important Austrian laws for the prevention of money laundering and terrorist financing as well as compliance with internation…
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