A few weeks ago, Chainalysis hosted a fantastic "Women in Crypto" event, offering insightful perspectives from four industry leaders on the future of cryptocurrency compliance.
It's worth listening to the full hour to hear about the latest priorities at OFAC, FinCEN, the DOJ, and within the private sector. However, if you don't listen to it all, here are a few notable topics/comments that were brought up with some additional links:
- FinCEN reopened the comment period for its Notice of Proposed Rulemaking (NPRM) regarding certain transactions involving convertible virtual currency (CVC) or digital assets with legal tender status (LTDA). Comments may be made here and are due March 1st.
- Sign up for the FinCEN updates list ("It's better than Twitter")
- Two of the latest enforcement actions related to virtual currency:
- First Bitcoin “Mixer” Penalized by FinCEN for Violating Anti-Money Laundering Law.
- OFAC Enters Into $98,830 Settlement with BitGo, Inc. for Apparent Violations of Multiple Sanctions Programs Related to Digital Currency Transactions
- The AML Act of 2020 develops stronger grounds for money laundering and BSA prosecutions by expanding the definition of financial institution and money transmitting business to include businesses engaged in the exchange or transmission of “value that substitutes for currency,” potentially reinforcing the government’s position that the BSA applies to cryptocurrency. See some of the changes related to technology and data here.
For investigations related to the above, the data breadcrumbs are pivotal and include transactional activity, communications, IP logs, as well as various third party resources that assist with attribution and identifying indicators of money laundering and terrorist financing.
As we look forward, expect government organizations to continue to work together globally to share policy, frameworks, and technical expertise.