A Risk-Based Approach For Virtual Currencies

This Guidance is intended to explain the application of the risk-based approach to AML/CFT measures in the VC context; identify the entities involved in VCPPS; and clarify the application of the relevant FATF Recommendations to convertible virtual currency exchangers. This Guidance is also intended to help national authorities understand and potentially develop regulatory responses including the need to amend their national laws in order to address the ML/TF risk of VCPPS. This Guidance is also intended to help the private sector better understand the relevant AML/CFT obligations and how they can effectively comply with relevant requirements. The Guidance incorporates the conceptual framework and key terms adopted by the FATF in the June 2014 VC Report (Appendix A), and readers are referred to that document for discussion of potential use cases for VC and a glossary of terms.

The Guidance seeks to: a) Show how specific FATF Recommendations should apply to convertible virtual currency exchangers in the context of VCPPS, identify AML/CFT measures that could be required, and provide examples; and b) Identify obstacles to applying mitigating measures rooted in VCPPS’s technology and/or business models and in legacy legal frameworks.



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