Blockchain Forensics and Compliance: Two Peas in a Pod

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For businesses engaged in cryptocurrency, transaction monitoring is an important part of their compliance programs. Businesses such as Bitcoin ATM (BTM) operators should monitor transactions on an ongoing basis for suspicious activity such as money laundering and for connections to sanctioned parties. These businesses should also know that there are effective tools they can use …

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Often Dealing with Cryptocurrency? Your Business Could Be An MSB, with AML, Sanctions Obligations

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Companies regularly engaged with cryptocurrency often meet the criteria to be money services businesses (MSBs) under federal regulation and are required to implement anti-money laundering programs and ensure OFAC sanctions compliance. This article will explore why such businesses are often MSBs under federal law, what kinds of MSBs such businesses are, and the basics of …

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Cryptocurrency Viewed Through the Three Stages of Money Laundering

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It’s not really necessary to rewrite the anti-money laundering manual for cryptocurrency, but a willingness to understand novels ways cryptocurrency can be used in the money laundering process will go a long way toward effective cryptocurrency AML practices. The same three stages used to describe the money laundering process involving cash (placement, layering and integration) …

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Targeted Sanctions May Be Best Tool To Combat Rogue Cryptocurrency Exchanges

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Not all cryptocurrency transactions need to be viewed as suspect. In fact, a 2019 evaluation by Chainanalysis indicates a significantly lower percentage of economic bitcoin activity was comprised of illicit transactions in 2018 than in 2012. But just because more legitimate economic actors are using cryptocurrency doesn’t mean that bad actors aren’t still exploiting cryptocurrency’s vulnerability. This …

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AML Risks Mean Financial Institutions Need Caution When Working with Cryptocurrency

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It is not a secret that cryptocurrency presents anti-money laundering and counter terrorist financing issues for financial institutions. But what is it exactly about cryptocurrency that makes it so risky? A 2018 Allen & Overy article explains the unique issues for financial institutions presented by cryptocurrency from an anti-money laundering perspective. In some respects, the challenges presented …

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2020 Saw EU Member States Take Big Step to Legitimize Use of Cryptocurrency

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The date for EU Member States to implement into national legislation the Fifth European Union Anti-Money Laundering Directive (AML 5) came and went this past January, and this was a significant development. AML 5, which makes several steps toward strengthening the EU’s anti-money laundering and combatting the financing of terrorism regulatory scheme, is especially important for …

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Effective AML Compliance at Cryptocurrency Exchanges

There is a lot of talk in the emerging cryptoeconomy as to when regulations apply to crypto-oriented services, but when it comes to Anti-Money Laundering (AML), Know Your Customer (KYC), and Combating the Finance of Terrorism (CFT), there is also the question of what an effective cryptocurrency compliance program might look like. Craig Adeyanju at …

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AML Regulations for Financial Institutions Entering the Cryptoeconomy

Whether financial services companies are actively engaged in the cryptoeconomy revolution or are watching it develop while planning for the future, there is increased interest in the relevant technologies and the questions of how companies can adapt. One question financial services companies have is how these technologies are and will be regulated, and in particular, …

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