The paper examines one aspect of the interaction between the
EU’s payment and crypto-asset services regulatory regimes. It finds that a de
lege lata (positive law) analysis, based on a literal/textual and systematic
interpretation, is inconclusive. Thus, it proceeds to a contextual-teleological
analysis and sketches elements to be taken into account in a de lege ferenda
(normative law) exploration of the subject. It examines, albeit briefly, the
historical evolution of the nature of money, in general, and payments as a debt
transfer mechanism, in particular; and it explores how the atomic settlement
enabled by the blockchain has been affecting the regulation of money and
payments- conceptually and in the particular EU context. It concludes that, in
light of the ensuing ‘end of silos’, the EU with its specific institutional
architecture, relying on the European Supervisory Authorities, augurs well for
a balanced regulatory responses, anchored in practical supervisory experience.