What to expect from the new FATF crypto-guidelines?

What is FATF

Recommendations and Guidelines

FATF has operated by releasing a set of Recommendations and subsequent interpretative guidelines. The latest set of Recommendations was released in 2012. Periodically then — whenever new developments arise — it is necessary to re-interpret the Recommendations based on the new developments. Therefore new interpretative guidelines are regularly released. In February 2019 an Interpretative Note was issued, which then became final in June 2019 when this new set of guidelines — dealing with VA and VASPs — has been released.

Background — Virtual Assets and Virtual Asset Service Providers

This new set of guidelines is applicable to VAs and VASPs as they were defined in the previous October 2018 guidelines.

How VASPs will be impacted by the Guidelines

The guidelines update and impact in particular the existing Recommendations nr. 10 and 16.

Comments and practicalities

Frankly, I miss the rationale behind the above provisions which are mostly unenforceable and of little practical use and which will not adversely impact ML/TF activities but will rather increase compliance costs, needless paper-work and maybe slow down the growth of the crypto sector in those countries which will implement them.

Conclusions

courtesy of shutterstock.com
Practically, the US are — more or less — in bad terms with more than two thirds of the world
US Treasury Secretary Steve Mnuchin put his weight behind the FATF guidelines released in June 2019
A non-custodial BTC address and its public and private keys

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