Effective anti-money laundering and combating the financing of terrorism regulatory and supervisory framework : some legal and practical considerations

The purpose of this note is to discuss the necessary anti-money laundering and combating the financing of terrorism (AML/CFT) measures and provide examples of practical solutions to implement them. In June 2020, the Financial Action Task Force (FATF) noted that both the public and private sectors have made progress in the implementation of the standards for virtual assets (VA), in particular through updates to national laws and the development of solutions to assist with the travel rule. However, challenges remain; many virtual asset service providers (VASPs) are only beginning to adopt the required AML/CFT measures, a number of jurisdictions are yet to implement the standards for VA and those that have are at the early stages of developing a supervisory regime for VASPs. At the time of drafting, no country had been assessed against the new standards and many country authorities were in the process of establishing how best to incorporate the new standards in their AML/CFT framework. For these reasons, this note does not refer to specific country examples. References to specific products and projects are made for illustrative purposes only and do not constitute an endorsement of these initiatives. This Fintech Note is based on the FATF standards and guidance, in particular those aspects that pertain to VA and VASPs