UAE’s anti-money laundering physique endorses framework for digital belongings

A general view of the Business Bay Area after a curfew was imposed to prevent the spread of coronavirus disease (COVID-19) in Dubai, United Arab Emirates, March 28, 2020. REUTERS / Satish Kumar / File Photo

DUBAI, Sept. 8 (Reuters) – A United Arab Emirates anti-money laundering committee has approved a regulatory framework for virtual assets, the Gulf State central bank said on Wednesday.

The National Committee on Combating Money Laundering and the Financing of Terrorism and Illegal Organizations has “announced the adoption of a regulatory framework for virtual assets in the UAE that is in line with approved anti-money laundering and counter-terrorist financing standards,” according to the central bank – that is one of the committee members – said in a statement.

The central bank and the Securities and Commodities Authority have been tasked with overseeing the implementation of the rules, the statement said.

“This regulatory framework is a first step towards comprehensive regulation of virtual assets and protects the financial system and investors from money laundering and terrorist financing risks,” it said.

In 2019, the Financial Action Task Force, the financial crime regulator, announced that cryptocurrency companies would be subject to rules to prevent misuse of digital coins such as bitcoin for money laundering. It was the first global regulatory attempt to contain the rapidly growing sector.

Reporting by Davide Barbuscia; Editing by Mark Porter

Our standards: The Thomson Reuters Trust Principles.

Crypto change Binance tightens anti-money laundering checks after regulatory stress

  • Binance is rolling out stricter background checks
  • Changes introduced with immediate effect
  • The pressure from regulators has increased in recent weeks

FRANKFURT, Aug. 20 (Reuters) – Major cryptocurrency exchange Binance said Friday it would call for stricter background checks on customers with immediate effect to aid anti-money laundering efforts.

Binance, the world’s largest platform, has come under pressure for the past few months from regulators around the world who are concerned about crypto’s potential for money laundering and the risks to consumers from volatile crypto trading.

The exchange, whose holding company is registered in the Cayman Islands, has reduced its product offerings, including leveraged trading and tokens linked to stocks, and announced that it intends to improve relations with regulators. Continue reading

The money laundering potential of cryptocurrency exchanges has long troubled regulators, including U.S. Treasury Secretary Janet Yellen and European Central Bank President Christine Lagarde, who raised concerns earlier this year.

The Dutch central bank said Monday that Binance was failing to comply with its anti-money laundering and terrorist financing laws.

Binance announced on their website that users would have to go through a verification process in order to access their products and services. Those who have not done so can only withdraw funds, cancel orders and close positions.

Until now, document-based ID checks at Binance were only required for users who wanted higher trading limits. Users will now need to upload an ID, driver’s license or passport to prove their identity, Binance said.

“This will further improve user protection and fight financial crime,” said the move.

Binance CEO Changpeng Zhao, a Canadian known by his nickname “CZ”, tweeted a link to Binance announcementsays “Actions speak louder than words”.

The steps taken by crypto exchanges to perform identity and background checks remain different, with some requiring full documentation and others allowing users to sign up for accounts with just one email address.

Binance’s spot trading volume was $ 455 million in July, almost a third less than the previous month, but still number 1 in the world according to data from CryptoCompare.

Binance’s corporate structure is opaque, although the holding company is registered in the Cayman Islands according to UK court documents and the Malaysian Securities Commission.

Reporting by Krisztian Sandor in Frankfurt and Tom Wilson in London; Writing by Tom Wilson Editing by Rachel Armstrong and Elaine Hardcastle

Our standards: The Thomson Reuters Trust Principles.

New Anti Anti-Cash Laundering Providers for Crooks – Krebs on Safety

A new dark web service is being marketed to cyber criminals curious how their various cryptocurrency holdings and transactions can be linked to known criminal activity. Synchronized “Anti-analysis “, The service is intended to provide insight into how law enforcement agencies and private companies might flag their own payment activities trying to link suspicious cryptocurrency transactions to real people.

Sample provided by Anti-Analysis.

“Concerned about dirty funds in your BTC address? Take a look at Antinalysis, the new address risk analyzer, ”says the service’s announcement, referring to a link that is only accessible via ToR. “This service is aimed at people who need complete privacy on the blockchain and offers an adversary perspective so the user can understand the possibility that their money is being flagged under autocratic illegal charges. ”

The display continues:

Some people may ask why go into all of this? Simply withdraw in XMR and you’re done. The problem is that paying out in Monero raises eyebrows at exchanges and mailing it in cash is sometimes risky too. If you use the BTC-> XMR-> BTC method, you will still be flagged by our services which are flagged as high risk exchanges (not to mention LE and exchanges). Our service offers you a look from the perspective of LE / exchange (with similar accuracy, but completely different approach), which gives you a basic understanding of how “clean” your address is. “

Tom Robinson, Co-founder of the blockchain intelligence company Elliptical, Antinalysis said to help crypto-money launderers test whether their funds are being identified by regulated financial exchanges as the proceeds of crime.

“Cryptoassets have become an important tool for cyber criminals,” Robinson said wrote. “Ransomware and darknet markets depend on payments in Bitcoin and other cryptocurrencies. However, washing and paying out this income is a great challenge. “

Cryptocurrency exchanges use blockchain analytics tools to screen customer deposits for links to illegal activity. By tracking a transaction through the blockchain, these tools can determine if the funds came from a wallet that is linked to ransomware or other criminal activity.

“The launderer therefore risks being identified as a criminal and reported to law enforcement agencies if he sends money to a company using such a tool,” said Robinson. “Antinalysis wants to help crypto-launderers avoid this by giving them a preview of what a blockchain analysis tool will do with their Bitcoin wallet and the funds it contains.”

Each Antinalysis lookup costs approximately $ 3 with a minimum purchase of $ 30. Other plans go up to $ 6,000 for 5,000 requests.

Robinson says the creator of Antinalysis is also one of the developers of Incognito Market, a darknet marketplace that specializes in the sale of narcotics.

“Incognito was launched in late 2020 and accepts payments in Bitcoin and currency, a crypto asset that offers increased anonymity, ”he wrote. “The introduction of Antinalysis likely reflects the difficulties that the market and its providers are facing in cashing out their Bitcoin proceeds.”

Elliptic wasn’t impressed with the quality of the information Antinalysis provided and said it did poorly at detecting links to major darknet markets and other criminal entities. But with countless criminals now making millions on ransomware, there is certainly a huge, untapped market for services that can help these people improve their operational security.

“It is also important because it is the first time it makes blockchain analytics available to the public,” wrote Robinson. “So far, this type of analysis has mainly been used by regulated financial service providers.”

That may not be entirely true. Nick Bax is an independent expert in tracking cryptocurrency transactions, and he said that Antinalysis appears to be little more than a clone of AMLBot, an anti-money laundering intelligence agency that first went online in 2019. AMLBot’s first advertisement was in Russian, while Antinalysis first appeared in an English-speaking darknet market.

The AMLBot user interface.

“It looks almost identical to the cheap version of AMLBot,” Bax told KrebsOnSecurity. “My guess is they’re just doing this white labeling.”

Bax said a look on AMLBot at the virtual currency address used in the sample provided by Antinalysis shows a nearly identical result. Here is the result from AMLBot for the same cryptanalysis performed by Antinalysis in the screenshot above in this story:

Response from AMLBot for the same cryptocurrency address provided as an example by Antinalysis.

“If you look at the breakdown, the percentages are all almost identical,” said Bax. “I use ALBot on occasion for good and righteous purposes. And it could also be useful for people who only sell things online to make sure they don’t get any tainted funds. “

Update, 1:42 p.m. ET: The story has been corrected to state that AMLBot has existed since 2019.

Japan Sees Cryptocurrency Sellers as A part of Anti-Cash Laundering Plan, Prime Monetary Regulator Says

Japan’s leading financial regulator said its planned anti-money laundering platform could include cryptocurrency traders, who it believes have the same obligation as traditional financial institutions to ensure they don’t deal with criminals.

The Financial Services Agency has announced that it will create a common industry-wide system that financial companies can use to assess whether their customers are terrorists and whether customer accounts are at risk of money laundering.

“Insofar as they are prohibited from trading with sanctioned people, cryptocurrency dealers are the same as banks,” said FSA chief Junichi Nakajima in an interview with the Wall Street Journal.

“Because we have the same list of international terrorists, it would be cheaper and more accurate if we create a common system instead of doing it from individual financial firms,” ​​said Nakajima, who took up his post in July.

Mr Nakajima said his agency expects to have a plan for the new platform by the middle of next year.

Anti-Cash Laundering Market Generated $2.four Billion Income in 2020: P&S Intelligence

NEW YORK, July 19, 2021 / PRNewswire / – The growing need for money laundering surveillance and the increasing adoption of anti-money laundering (AML) solutions in the public and private sectors are driving the expansion of the global Anti-money laundering market. In addition, the increasing number of money laundering and other illegal activities such as sanctions violations and skimming as well as the adoption of strict rules and regulations by the governments of several countries are driving the development of the market. Because of these factors, the market reached $ 2.4 billion Revenue in 2020, and according to P&S Intelligence, a huge expansion is forecast between 2021 and 2030.

Get the sample copy of this report at:

The COVID-19 pandemic has had a positive impact on the growth of the anti-money laundering market. With lockdowns imposed in several countries, the use of digital banking services, e-wallets and digital payments has increased massively. As there is a need to make these platforms and services secure, their increasing adoption is driving the demand for AML software and solutions.

The global anti money laundering market is divided into banks and other financial institutions, gaming and gambling, and insurance providers depending on the end user. Of these, the banks and other financial institutions category dominated the market in 2020. This is due to the growing need for AML solutions from banks and other financial institutions due to the increasing prevalence of illegal activities such as fraud, money laundering, and phishing.

Search detailed report with COVID-19 impact analysis in the anti-money laundering market research report: By Type (Solutions, Services), Deployment Mode (Cloud, On-Premise), Organization Size (Large Enterprises, SMEs), End Users (Banks and Other Financial Institutions, Insurance Providers, Gaming & Gambling Sector) – Global industry analysis and growth forecast up to 2030 @

Geographically, North America dominated the anti-money laundering market in 2020. This is attributed to the existence of multiple industry players, the increasing prevalence of money laundering cases and the large-scale adoption of advanced technologies such as artificial intelligence (AI) in the region.

The players in the anti-money laundering market are focused on developing new products in order to reach more customers and expand their presence. Tata Consultancy Services Limited (TCS), for example, has developed the TCS BaNCS, a banking software suite that supports the processing of real-time data in May 2019 to retail banks in Canada deal better with payment problems.

Find out more before buying:

NICE Actimize, a subsidiary of NICE Systems Ltd., has also launched an AI-based surveillance solution called SURVEIL-X September 2019. This solution detects different types of risky behavior and helps financial services companies quickly build and review risk detection models to manage operational risk and ensure regulatory compliance.

ACI Worldwide Inc., Nice Systems Ltd., BAE Systems plc, Fair Isaac Corporation (FICO), LexisNexis Risk Solutions, SAS Institute Inc., Dixtior, Fiserv Inc., TransUnion LLC, Temenos AG, Wolter’s Kluwer Limited, Nelito Systems Ltd. , Featurespace Limited, Tata Consultancy Services Ltd. (TCS), Finacus Solutions Private Limited, Feedzai Inc., Comarch SA and CaseWare RCM are some of the key players in the anti-money laundering market.

Browse other reports

BFSI security market – The global BFSI security market was created with. rated $ 31.3 billion in 2019, which is expected to be achieved $ 175.1 billion by 2030 with a CAGR of 16.9% in the forecast period (2020–2030). The increasing emphasis on integrated security services is one of the major trends in the BFSI security market.

Fraud Detection and Prevention Market – The global fraud detection and prevention market has been expanded with $ 20,614.4 million in 2018 and is expected to increase with a CAGR of 15.1% in the forecast period (2019-2024). Together, North America and APAC are projected to account for 67.5% of the fraud detection and prevention market in 2024.

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P&S Intelligence is a market research and advisory service provider serving the market intelligence needs of emerging industries around the world. As an enterprising research and advisory firm, P&S provides the foundation for market intelligence and believes in thorough landscape analysis of the ever-changing market scenario to enable companies to make informed decisions and strategize their business with ingenuity.


Prajneesh Kumar
P&S intelligence
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E-mail: [email protected]


SOURCE P&S Intelligence

How reporting for ICIJ ready me to change into a licensed anti-money laundering specialist

As an investigative reporter, I’m used to not making many friends at work.

Your integrity – and intelligence – is regularly challenged. “It’s complicated,” say the subjects of our investigations into financial crime, tax avoidance and the offshore industry. ‘You have no idea what you are talking about.’

I remember an especially sharp email from a high-paying musician’s rep in response to simple questions about an offshore bank account: “It’s difficult to express astonishment at the receipt of your email in writing. It contains references to allegations of the most bizarre kind. “

To them I say … CAMS!

Earlier this year, I passed a test that allowed me to add four words after my name: Certified Money Laundering Specialist.

The CAMS accreditation granted by a leading Association by anti-money laundering specialists, is primarily intended for people who work in banks, financial services companies and other companies to prevent criminals as much as possible from sending, receiving or moving what we often call “dirty money” or the proceeds from a crime. These are the people who are meant to stop what you see in movies. They know the crux of the matter: a drug cartel sells cocaine, then they count stacks of 100 dollar bills in a kitchen and transfer the money to a secret bank account in Switzerland before buying a luxury condo in Miami.

Stopping this type of wrongdoing is no easy task. Many criminals are much smarter than they were 20 years ago, when it was easier to walk into a hotel with a briefcase full of cash and bribe a foreign official. In addition, these specialists in charge of labeling and blocking criminal cash can sometimes encounter resistance within their own bank – CAMS are often the ones who advise their colleagues to say “no” to potentially lucrative customers.

Talking to such specialists is part of my job as a reporter at the International Consortium of Investigative Journalists. And that’s not just me. Of Panama papers to FinCEN files, hundreds of reporters working with the ICIJ on our groundbreaking investigation regularly interview anti-money laundering specialists. (Thanks for answering our calls, everyone!)

We ask questions like: Does that sound suspicious? What laws did Deutsche Bank have when it helped the repressive government of Turkmenistan? Send $ 1.6 million to a recently formed mailbox company in Scotland to buy “confectionery”? What legal responsibilities do you have, if any? Lawyers, accountants and bankers before you agreed to partner with Angolan billionaire Isabel dos Santos? What does the United Arab Emirates so stupid?

For a couple of months I set aside an hour or two a day for study. Flash cards? Check. Online Lectures? Check. Practice quizzes? Check. A 316-page memorization manual? Check. I drowned in acronyms: FATF, GAFILAT, NCCT, MLAT, AMLID, MSB, DNFBP.

When I took the exam in March, I felt well prepared. But at several points during the 210-minute test, I was convinced that I would fail. What would i say to my friend Or worse, my bosses?

My friend made a sign to me to celebrate passing the CAMS test. Image: Will Fitzgibbon

I passed by and breathed a sigh of relief.

I was pleasantly surprised at how well my work at ICIJ had prepared me.

But what really excited me, aside from my new qualification and nerdy bragging rights, was the realization that years of global collaboration in the offshore financial system has also produced an army of journalists like me with anti-money laundering experience in the workplace. Let’s call it “CAMS-by-doing”.

For more than seven years, I have joined hundreds of reporters from around the world on many of the ICIJ’s best-known financial investigations Swiss leaks to the Panama papers to Leaks in West Africa to the FinCEN files.

Together we read thousands of emails, contracts, spreadsheets, and financial statements. We interviewed thousands of experts. Slowly but surely, journalists like me who have worked on ICIJ research have built a knowledge base that would read like a dedicated CAMS study guide.

Most of us (myself included) are not and never will be experts. But every year we improve our knowledge of where to look and what questions to ask. Our BS-Radar has become more precise, if you will: Why should a Canadian company founded with gold mine in Senegal a company without employees in Mauritius? Why should a Cellist and close friend Russian President Vladimir Putin’s rights to a $ 200 million loan for just $ 1?

Sure, I’m a CAMS now. But the world should be more careful: with years of ICIJ investigations, there are now hundreds of other reporters out there, just like me, better than ever at spotting a seedy deal when they see one. I’m excited to see what we all do next.

Crooks, watch out.

NAB Investigated For Potential Anti-Cash Laundering Regulation Breaches

By Alice Uribe

SYDNEY – The National Australia Bank Ltd. will undergo a formal review by the Australian Financial Intelligence Authority on concerns that it has violated anti-money laundering and terrorist financing regulations.

The Australian bank said AUSTRAC signaled in a letter dated Jan.

These concerns have been passed on to AUSTRAC’s enforcement team, which has opened a formal investigation, NAB said.

Nevertheless, AUSTRAC said in the letter that it had not made a decision as to whether enforcement measures would be taken and that, given the work of the NAB to date, it was not considering civil criminal proceedings.

Write to Alice Uribe at

The Anti-Cash Laundering Act and Crypto Collide: Non-Fungible Tokens | King & Spalding

As NFTs gain popularity, buyers and sellers should consider the potential issues related to federal anti-money laundering laws.

While non-fungible tokens (“NFTs”) have existed for several years, the market for NFTs grew considerably during 2020 and into 2021, as a number of high-profile NFT sales grabbed headlines and well-known brands and organizations began exploring the use of NFTs. Amid this continued growth in adoption, and the expanding range of use cases, industry participants should make sure they are aware of the legal implications for issuing, purchasing, and trading these new assets.

For now, existing laws and regulations will likely be applied to promote transparency and to address several aspects of NFTs, including the potential investment value, the risk of speculation and volatile pricing, and potentially anonymous market participants. This article, which is the first in a multi-part series highlighting the legal and regulatory implications surrounding NFTs, explores the current state of play, potential risks, and likely regulatory developments relating to NFTs and federal anti-money laundering laws.


NFTs are digital assets encoded on a blockchain that represent ownership of a unique asset or set of rights. Most blockchain tokens that represent digital assets (including cryptocurrencies) are fungible, meaning that the characteristics of any two tokens are the same. As a result, any two fungible tokens of the same type will generally have equal value. The technology underlying NFTs, on the other hand, ensures that each token is unique, and NFT creators have leveraged those characteristics of the technology to create a broad range of unique digital assets. NFTs range from digital artwork (including the $69 million sale of an NFT by digital artist Beeple),1 to virtual real estate (one buyer recently purchased nine digital plots of land in an online game for approximately $1.5 million),2 to digital Lebron James trading cards,3 to virtual race horses,4 to an entry ticket for a virtual celebrity beer pong tournament.5 NFTs are “minted” by issuers or creators and purchased through online exchanges or marketplaces.

NFTs are not limited to the digital space; rather, they “can also represent any type of physical asset, acting as a kind of ‘digital twin’ to anything existing in the real world and enabling the ownership and exchange of physical possessions within digital marketplaces.”6 One key characteristic of NFTs is provable ownership—that is, given the reliability of blockchain technology and decentralized ledgers, an NFT holder can be confident that his or her ownership of the underlying asset(s) is secure. NFTs are accompanied by “smart contracts,” which allow the seller to place conditions on the token-holder’s ownership rights, such as generating automatic royalty payments to the original NFT creator at each subsequent sale.7 The conditions of an NFT’s underlying smart contract are designed to be automatically enforced by the NFT’s code on the blockchain.

According to one study conducted in partnership with a financial institution, the NFT market has grown rapidly in recent years:8





Active Wallets*




USD Traded

$159.1 million

$62.9 million

$250.8 million

Market Capitalization

$40.9 million

$141.6 million

$338 million

* Wallets allow users to send, receive, and spend cryptocurrency. This row indicates the # of wallets that have interacted with an NFT Smart Contract, including buyers, sellers, and anyone who has played a game or interacted with a project using NFTs

And that trend has continued during 2021. Indeed, one report shows that NFT sales in the first quarter of 2021 grew to more than $2 billion, over twenty times the volume of the previous quarter.9 On one major marketplace, NFT sales grew from $8 million in January 2021, to $95 million in February, to almost $150 million in March.10 While sales volume dropped to $94 million in April, the larger trend shows a marked increase from last year, during which the same marketplace had an average sales volume of only $1 million per month.11


As the digital art world grows and prices soar, NFT marketplaces specializing in digital art may become subject to suspicious activity reporting standards under the Bank Secrecy Act (“BSA”). On January 1, 2021, Congress passed the Anti-Money Laundering Act of 2020 (“AMLA”) which provides the most comprehensive update to anti-money laundering laws under the BSA since the Patriot Act.12 Both the AMLA and BSA enable the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) to regulate the activity of financial institutions, including through various recordkeeping and reporting obligations. Although the AMLA does not directly mention NFTs, several provisions ought to be considered by individuals and financial institutions contemplating NFT transactions.

Is an NFT a “value that substitutes for currency or funds”?

Although the AMLA formally extended BSA reporting obligations to cryptocurrency exchanges, direct regulation of NFTs and related marketplaces will require additional action by Congress. Section 6102(d) of the AMLA expanded the definition of “financial institutions” to include businesses involved in the exchange of “value that substitutes for currency or funds,” thus codifying FinCEN’s longstanding position that cryptocurrency exchanges—which convert fiat currency such as the U.S. dollar into cryptocurrency and vice versa—are “money services businesses” subject to BSA reporting requirements.13 This requires cryptocurrency exchanges to engage in customer due diligence (“CDD”) to verify the identity of their customers, identify any beneficial owners of accounts, develop customer risk profiles, and monitor transactions to submit suspicious activity reports among other things.14

Cryptocurrencies are clearly a “value that substitutes for currency,” but it is less likely NFTs would be deemed the same. Currencies and their substitutes derive their utility, in part, from their inherently fungible nature.15 Generally speaking, NFTs would not be considered a currency nor a substitute because, by definition, they lack fungibility. NFTs are more akin to legal instruments, such as a deed, containing a unique signature demonstrating ownership of an asset. That lack of fungibility arguably pushes NFTs outside the reach of the AMLA, and further action from Congress would be necessary to apply anti-money laundering regulations to NFTs and their marketplaces directly.

FinCEN has yet to issue anything specifically on NFTs, and has similarly not indicated whether NFT players are or may become subject to the AML regime. That said, regulators have certainly begun formalizing procedures for applying current laws to digital assets. Just one example is DOJ’s recently published Asset Forfeiture Policy Manual that provided guidance regarding seizure of cryptocurrencies and digital tokens.16 And given the high degree of scrutiny and ongoing expansion of AML obligations to the cryptocurrency space, NFTs may not escape additional rulemaking or legislation.

Are NFT marketplaces “art dealers”?

Congress is in the process of expanding the BSA’s reach and could reasonably conclude that NFT exchanges should be included among the list of entities subject to the law’s reporting requirements.

The AMLA sought to address, among other things, the multibillion-dollar black market trade in art and antiquities, which is estimated to be the “third largest type of black market after illegal drugs and the arms trade.”17 Forthcoming regulations from FinCEN are expected to expand BSA reporting obligations to antiquities dealers, and in January 2022 Congress is scheduled to receive the results of an ongoing study by FinCEN that will “inform debates over whether to extend BSA requirements to art dealers.” 18 As discussed more fully below, extending reporting obligations to art dealers could have the effect of sweeping NFT exchanges into the scope of such obligations. If reporting obligations are extended, art dealers will be required to grapple with a number of anti-money laundering protocols more familiar to financial services entities. The rule would also make it far more difficult for buyers and sellers to obscure their identities through shell companies or offshore entities.

NFT marketplaces such as OpenSea, Rarible, and SuperRare function much like an auction house or an art dealer by connecting buyers and sellers who transact directly. In fact, SuperRare describes itself as “Instagram meets Christies,”19 and Mark Cuban is building an online art gallery to display his NFTs.20 Given their similarities, NFT marketplaces share many of the characteristics that make the art trade susceptible to money laundering—namely, “buyer secrecy, informal and self-regulated markets, non-transparent pricing, [and] high value transactions.”21 In early March, for example, an NFT consisting of a digital copy of a limited-edition Banksy print sold for nearly $400,000 in Ethereum on OpenSea to a bidder with the screen name “GALAXY,” whose profile lacks any identifying information.22 The buyer behind the $69.3 million sale of Everydays: The First 5000 Days by Beeple was also initially pseudonymous, although the purchaser later revealed his identity.23 Given that many of these transactions are completed using cryptocurrencies—which can be hard to trace to actual individuals—the NFT trade faces similar money laundering risks as the art trade more generally.24 Of course, as Congress considers subjecting art dealers to the BSA, it could also decide to define “art dealers” broadly to bring NFT marketplaces specializing in digital art within the BSA’s ambit. In addition, several prominent auction houses have started to participate in NFT sales,25 and those firms should be mindful that the compliance considerations applicable to traditional art sales should be applied to NFT sales as well.

NFTs and anti-money laundering risks from “tumblers”.

So-called “tumbling” poses an added layer of anti-money laundering concerns with respect to NFTs. One distinct feature of cryptocurrencies is that the ownership history of a particular coin can be traced.26 In theory, one can trace the owner-history of cryptocurrencies because each transaction involving a particular coin is publicly recorded on the blockchain.27 Cryptocurrencies are held in virtual “wallets” which function as the digital address, or identity, of the wallet holder.28 When a cryptocurrency coin is passed to another wallet, the data is recorded in a transaction “block” which lists the digital wallet addresses of the sender and recipient.29 Each transaction block is then automatically recorded and stored publicly on the blockchain, which functions as a public digital ledger of all transactions.30 Working backwards, it is generally possible to trace the ownership history of a coin by analyzing the coin’s transaction blocks to see all of the digital wallets through which it has passed.31 Although the digital addresses of each wallet do not directly identify the actual owner, wallets can be linked to real people by mapping IP addresses and other forms of data analytics.32

Cryptocurrency “tumblers” can increase the difficulty of tracing a coin’s ownership history, however, by circulating that coin through multiple transactions33 and thus “washing” its potential connection to suspicious wallets or transactions.34 Significant time, patience, data, and processing power is required to “untumble” coins—the more a coin is tumbled, the harder it is to trace.35

FinCEN guidance considers cryptocurrency tumbling to be a “money transmitting business,” thus requiring registration with FinCEN, compliance with both BSA reporting requirements and “know your customer” due diligence obligations, and implementation of an anti-money laundering compliance program.36 This guidance has been tested and upheld in United States v. Harmon, an ongoing criminal money laundering case against Larry Dean Harmon for operating Helix—a tumbling service that was allegedly used on the dark web to conceal cryptocurrencies used for black-market activities.37 Harmon was indicted for money-laundering and operating an unlicensed monetary business in violation of the BSA. In upholding the indictment, the court noted that tumblers “work by literally mixing up a user’s payment with lots of other payments from other users” to obfuscate their ownership history, thus qualifying as a “money transmitting business” by “receiving bitcoin and transmitting that bitcoin to another location or person.”38 The Harmon prosecution is still ongoing with jury selection set for later this year,39 and it is possible that the district court’s rationale in upholding the indictment could be reevaluated on appeal.

Theoretically, NFT marketplaces could be leveraged to achieve the same result as tumbling.40 Given the extraordinarily high value of some NFTs, individuals could execute multiple NFT transactions whereby a significant number of coins are spread to different accounts. Repeating this process over and over, individuals could distance themselves from coins linked to dark web activities or cryptocurrency exchanges that do not comply with anti-money laundering and customer due diligence requirements. In short, NFT transactions could be used as another way to add multiple “blocks” to a coin’s ledger, thereby obfuscating the transaction history and associated accounts.41

Although NFT marketplaces may in some cases help obfuscate ownership of cryptocurrency linked to illicit activities, NFT marketplaces are unlikely to qualify as a “money transmitting business” because they merely (1) allow NFT purchasers and sellers to connect and transact without an intermediary (i.e., a “peer-to-peer” platform) and (2) do not directly handle or otherwise process the cryptocurrencies used to purchase NFTs. Indeed, one commentator described an NFT marketplace as “eBay on the blockchain.”42 Given that NFT marketplaces pose similar money-laundering risks as auction houses and art dealers involved with in high-value transactions, however, Congress could decide to independently subject NFT marketplaces to BSA reporting requirements, “know your customer” due diligence, and other requirements.

Regardless of future regulatory changes, crypto-exchanges and traditional financial institutions handling NFT transactions should beware of obligations for reporting suspicious activity.

Both cryptocurrency exchanges and traditional financial institutions are subject to the BSA and therefore may be required to file suspicious activity reports (“SARs”) for transactions involving NFTs for digital art and other tethered assets. In fact, recent guidance from FinCEN was issued to “provide specific instructions for filing SARs related to trade in antiquities and art.”43 Under the guidance, to comply with BSA obligations, financial institutions—a definition that now includes cryptocurrency exchanges—are required to submit SARs for suspicious activity related to art and antiquities. The guidance explains that SAR filings should:

  • include a detailed description of how the questionable activity is tied to art and antiquities;
  • provide identifying information (including IP addresses) for the purchasers, sellers, and any other intermediaries or agents; and
  • state the volume and dollar amount of the suspicious transactions.

Additionally, SARs ought to identify any “other transactions or proposed transactions that may involve antiquities or art” and identify where the reported individuals or entities are currently operating. Given the similar money-laundering risks shared between high-value art transactions and NFTs, financial institutions and cryptocurrency exchanges may be obligated to file SARs when executing NFT transactions on behalf of their clients. They should therefore have in place controls for identifying suspicious activity relating to NFTs, as well as determining when and how to report it.


Traditional financial institutions are no strangers to the stringent BSA and other anti-money laundering compliance requirements. Those institutions’ involvement with NFT-related transactions may generate new compliance obligations. Unless and until NFT-specific guidance is provided, companies should look to guidance on analogous services and products. Given the money-laundering risks shared between NFTs and the art and antiquities markets, financial institutions should pay special attention to the opaque and often anonymous NFT market and should consider filing SARs if they detect any suspicious activity related to an NFT transaction. In this rapidly evolving area, both financial institutions and cryptocurrency exchanges should also consider re-examining their existing anti-money laundering compliance programs to meet the needs of their clients and federal regulators.

1 Katie Tsai, “Digital Artist Beeple Sees NFTs, Like the One He Sold for Over $69 Million, Around for ‘Many Decades,’” CNBC (Apr. 30, 2021), available at

2 Janine Yorio, “Here Comes the Virtual Real Estate Boom,” CoinDesk (Feb. 16, 2021), available at

3 Jabari Young, “People Have Spent More Than $230 Million Buying and Trading Digital Collectibles of NBA Highlights,” CNBC (Feb. 28. 2021), available at

4 Taylor Lorenz, “Digital Horses Are the Talk of the Crypto World,” N.Y. Times (May 1, 2021), available at

5 Tanzeel Akhtar, “Social Token App Fyooz Offers Chance to Play Beer Pong with Rap Artist Post Malone,” Yahoo!Money, (Feb. 11, 2021), available at

6 See Non-Fungible Tokens Yearly Report 2020 (Free Version), & L‘atelier/BNP Paribas, PDF at 3 (Feb. 16, 2021), available at [hereinafter “NFT Yearly Report 2020”].

7 See Interview of Professors Burt Rosenberg and Tarek Sayed, University of Miami (Mar. 26, 2021), available at

8 NFT Yearly Report 2020, PDF at 26–27.

9 See Robert Frank, NFT sales top $2 billion in first quarter, with twice as many buyers as sellers, CNBC (Apr. 13, 2021), available at

10 See Elizabeth Howcroft, After first quarter frenzy, NFT market shows signs of stabilizing, Reuters (May 4, 2021), available at

11 See id.

12 Anti-Money Laundering Act of 2020, Pub. L. No. 116-283, H.R. 6395, 116th Cong. § 6101 et seq. (enacted Jan. 1, 2021) (to be codified at 31 U.S.C. § 5323), available at

13 Fin. Crimes Enf’t Network, U.S. Dep’t of the Treasury, FIN-2019-G001, Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies 3 (2019), available at

14 See 31 C.F.R. § 1010 et seq.

15 C.f. United States v. Faiella, 39 F. Supp. 3d 544, 545 (S.D.N.Y. 2014) (finding that Bitcoin qualifies as money precisely because “Bitcoin can be easily purchased in exchange for ordinary currency, acts as a denominator of value, and is used to conduct financial transactions”); United States v. Ulbricht, 31 F. Supp. 3d 540, 570 (S.D.N.Y. 2014) (defining “money” as “an object used to buy things” and concluding that “the only value for Bitcoin lies in its ability to pay for things” because “Bitcoins can be either used directly to pay for certain things or can act as a medium of exchange and be converted into a currency which can pay for things”). See also Sebastian Omlor, The CISG and Libra: A Monetary Revolution for International Commercial Transactions?, 3 Stan. J. Blockchain L. & Pol’y 83, 90 (“The two basic functions of money are to be a unit of account and a universal means of exchange.”).

16 See U.S. Dep’t of Justice, Asset Forfeiture Policy Manual 26 (2021), available at

17 Combating Illegal Antiquities Trade, Standard Charted Bank (Dec. 2018), available at

18 Transnational Crime Issues: Arts and Antiquities Trafficking, Congressional Research Service (Mar. 1, 2021),

19 Frequently Asked Questions, SuperRare (last visited May 3, 2021), available at

20 Shalini Nagarajan, Billionaire Mark Cuban is setting up a digital art gallery that allows users to display NFTs in any form, report says, Business Insider (Mar. 24, 2021), available at

21 Combating Illegal Antiquities Trade, supra at note 12, available at

22 See Jamie Redman, Burned Banksy NFT Sale Captures Close to $400K, Critics Claim Buyers Are ‘Morons’, (Mar. 8, 2021), available at; User Profile: “Galaxy”, OpenSea, available at

23 Robert Frank, Crypto investor who bought Beeple’s NFT for $69 million says he would have paid even more, CNBC (Mar. 30, 2021), available at

24 See United States v. Harmon, No. 19-CR-395-BAH, 2021 WL 1518344 (D.D.C. Apr. 16, 2021) (explaining the role of cryptocurrency “tumblers” in relation to multi-count money-laundering indictment against the operator of a tumbler service). For a general overview of the difficulty of tracing the ownership history of cryptocurrencies, see P. Vigna and C. Ostroff, Why Hackers Use Bitcoin and Why It Is So Difficult to Trace, Wall Street J. (July 16, 2020) available at

25 See, e.g., Lucas Matney, CryptoPunks NFT bundle goes for $17 million in Christie’s auction, TechCrunch (May 11, 2021), available at

26 See John Bohannon, Why criminals can’t hide behind Bitcoin, Science Magazine (Mar. 9, 2016), available at

27 See Study on Cryptocurrencies and Blockchain, E.U. Pol’y Dep’t for Economic, Scientific and Quality of Life Policies 17 (2018), available at

28 Id. at 17.

29 Id.

30 Id

31 See id. at 46.

32 See John Bohannon, Why criminals can’t hide behind Bitcoin, Science Magazine (Mar. 9, 2016), available at

33 See Mark Rash, Bitcoin Tumbling Leads to Multicount Indictment, Security Boulevard (Feb. 27, 2020), available at

34 Toshendra Kumar Sharma, How is Blockchain Verifiable by Public and Yet Anonymous?, Blockchain Council (last visited May 2, 2021), available at

35 See id.

36 See Fin. Crimes Enf’t Network, U.S. Dep’t of the Treasury, FIN-2019-G001, Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies 21 (2019), available at; see also 31 U.S.C. § 5330; 31 C.F.R. § 1022.380.

37 See United States v. Harmon, 474 F. Supp. 3d 76 (D.D.C. 2020) [Harmon I]; Harmon II, No. 19-CR-395 (BAH), 2020 WL 7668903 (D.D.C. Dec. 24, 2020); Harmon III, No. 19-CR-395 (BAH), 2021 WL 1518344 (Apr. 16, 2021).

38 Harmon I, 474 F. Supp. 3d at 82, 109 (quoting Usha R. Rodrigues, Law and the Blockchain, 104 Iowa L. Rev. 679, 712 n.224 (2019)).

39 See Joint Mot. to Continue Trial and Pretrial Dates, ECF No. 89, United States v. Harmon, No. 19-CR-395 (BAH) (D.D.C.).

40 According to Tim Swanson, Head of Market Intelligence for the London-based blockchain firm Clearmatics: “NFTs are just another way of achieving the same goal, of breaking down the provenance and walking away with ‘clean’ or screened coins.” See Simon Chandler, Money Laundering Might Taint NFTs Too, Prepare for Tighter Controls, CryptoNews (Mar. 27, 2021), available at

41 Id.

42 See Top NFT Marketplaces: Beginners Guide, DappRadar (Apr. 4, 2021), available at (“OpenSea is the first and biggest peer-to-peer NFT marketplace for crypto goods. You can think of it as eBay on the blockchain.”).

43 Fin. Crimes Enf’t Network, U.S. Dep’t of the Treasury, FIN-2021-NTC2, FinCEN Informs Financial Institutions of Efforts Related to Trade in Antiquities and Art 1 (2021), available at

The Anti-Cash Laundering Act of 2020: A Survey of Key Provisions and Apply Takeaways | Perkins Coie

On New Year’s Day 2021, Congress suspended a presidential veto to pass the 2020 Anti-Money Laundering Act (GwG 2020), which amends and modernizes the Bank Secrecy Act (BSA). The GwG 2020 includes comprehensive reforms to update and modernize the laws, rules and regulations to combat money laundering in the USA. While most of these reforms target financial institutions subject to the BSA, some have far-reaching implications for domestic and international business.

About the series

This multi-part series will highlight key findings from the 2020 AMLA that have practical implications for our clients, including (1) new and far-reaching requirements for beneficial ownership disclosure of companies that the Financial Crimes Enforcement Network (FinCEN) is currently actively working to implement; (2) increased incentives for whistleblowers to report money laundering violations; (3) Extension of the US subpoena to include foreign financial institutions with correspondent accounts in the United States; (4) New criminal penalties for disguising the involvement of senior foreign policy figures and certain Designated Bodies in transactions involving US financial institutions; (5) Extension of the Money Laundering Act to codify responsibility for activities in virtual currencies; and (6) developing regulatory solutions with a greater focus on emerging technologies. The following is a general overview of some of the topics covered in this series:

New disclosure requirements for beneficial ownership. Perhaps most importantly, the 2020 AMLA requires many Limited Liability Companies (LLC) to disclose their beneficial owners to the government – a new requirement that will apply to previously unregulated companies. The AMLA instructs FinCEN to keep a secure register of beneficial ownership rights of legal entities in order to facilitate investigations by law enforcement agencies and due diligence by financial institutions. This provision, which is aimed at Shell companies and other single-purpose vehicles, is designed to prevent the use of anonymous units to disguise the natural persons behind a company. On April 1, 2021, FinCEN published an advance notice of the proposed rulemaking, setting out the issues it is addressing in order to have the necessary rules in place by January 1, 2022 and asking the public for comments on how the rule of beneficial ownership should be implemented. The first part of this series will describe the expanded legal definition of beneficial owner, examine the long list of AMLA’s exemptions from registration requirements, and discuss some of the key lessons learned from FinCEN’s recent public announcement.

Significantly improved whistleblower incentives. The GwG 2020 will introduce a whistleblower program based on the program of the US Securities and Exchange Commission. These provisions encourage whistleblowers to report violations of the BSA and authorize higher financial rewards for those who provide information to their employers or the government. The availability of rewards for internal reporting is a provision that can be particularly problematic when the reporting employee and the company disagree on whether the conduct in question needs to be reported to regulators or otherwise. The second part of this series discusses these provisions in detail.

Extended subpoena. The 2020 AMLA expands the U.S. Department of Justice’s subpoena to include foreign financial institutions. It gives the Treasury Secretary and the Attorney General the power to issue subpoenas to foreign financial institutions holding correspondence accounts in the United States in relation to account information in their possession. This is a significant addition to the previous authorization, which was limited to records on US correspondence accounts. The third part of this series explains these new regulations and how they affect foreign financial institutions and foreign individuals and companies that are being investigated.

New penalties for covering up transactions with high-ranking foreign policy figures. Finally, the GwG 2020 amends the BSA to the effect that criminal sanctions are provided that forbid the deliberate concealment of transactions with high-ranking foreign policy figures and certain designated money laundering bodies in front of financial institutions. The prohibition specifically extends to anyone involved in the concealment, misrepresentation, or forgery (or attempt to cover up, misrepresentation or forgery) any financial institution having material facts relating to the ownership or control of assets in excess of US $ 1 million – Dollars by a senior foreigner political figure (or an immediate family member or close associate). The penalty sharpens the transaction diligence process and will no doubt improve the quality of care financial institutions receive when reviewing account holders and transactions. Like other recent anti-money laundering disclosure requirements – such as the real estate-related global targeting mandates that have been issued over the past few years and expanded continuously – this can have important implications for the expansion of anti-corruption enforcement. This determination is examined in the fourth part of our series.

Expansion of the Money Laundering Act to codify responsibility for activities in virtual currencies. The GwG 2020 codifies earlier FinCEN guidelines, according to which companies that carry out certain business activities in virtual currencies must register as money service providers. By expanding the definitions of terms such as “financial institution” and “money transfer business”, the new law includes companies that exchange or otherwise transfer virtual currencies or “values ​​that replace currencies”. FinCEN’s guidelines have been controversial in the industry and codifying them into law will create additional challenges and opportunities.

Developing an emerging financial technology focus. The GwG 2020 gives the financial supervisory authorities and the Government Accountability Office the impetus to conduct studies and submit reports to Congress and develop skills to better understand and adapt the legal framework in order to address emerging fintech technologies. The law instructs FinCEN to hire emerging technology professionals to identify emerging technologies such as artificial intelligence, digital identity technology, and distributed ledger technologies that can potentially aid government and financial institutions in combating money laundering and terrorist financing. Federal financial regulators are expected to investigate new payment methods, such as virtual currency and peer-to-peer payment systems, and provide reports to Congress on their use in money laundering and illegal activities. The federal financial supervisory authorities have promoted the use of emerging technologies by financial institutions, and the AMLA 2020 instructs FinCEN to set up a no-action letter procedure that enables the industry to find the technology solutions acceptable to the supervisory authorities for compliance with the To understand BSA better.

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Tookitaki Powers AI-Pushed Anti-Cash Laundering Answer Utilizing HPE GreenLake

Tookitaki, the leading regulatory technology company and HPE technology partner, is using HPE GreenLake to provide financial institutions in Asia Pacific with an enhanced anti-money laundering solution powered by AI and machine learning

Hewlett Packard Enterprise (HPE) today announced an important collaboration with Tookitaki, a leading provider of compliance solutions for the financial services industry, has launched a new offering for banks and financial institutions in the Asia-Pacific region. The new offer offers Tookitaki’s artificial intelligence (AI) anti-money laundering solution (AML) in a secure and flexible consumption model as a service HPE GreenLake for Big Data.

With the new solution, financial institutions can create a central big data platform that can perform AML data analysis and enable AI AML solutions. Delivering the solution as a service through HPE GreenLake gives banks the flexibility, flexibility and scalability of a cloud experience while providing more control, cost-effectiveness and governance when deploying AI-optimized infrastructure platforms and solutions on-site. UOB, a leading bank in Asia, is the first financial institution in the world to choose Tookitaki’s AML solution for HPE GreenLake to enhance the bank’s AML system through AI. UOB has adapted Tookitaki’s AI solution to the needs of the bank.

By working with Tookitaki and HPE, UOB was able to develop an AI-enhanced AML system that simultaneously applies two dimensions of AML risk – transaction monitoring and name verification. UOB uses the technology to review 60,000 account names each month to determine if they belong to the people or organizations on global watch lists. UOB’s AI-enhanced AML system can now pinpoint higher priority cases based on the more than 5,700 average monthly alerts of suspicious transactions that are flagged1. This enables the bank to deploy the resources required to investigate potential money laundering attempts in a more targeted and faster manner. The models used for name screening and transaction monitoring achieved a prediction accuracy of 96% in the “high priority” category.

The story goes on

“Moving from a successful pilot to implementing with UOB is a testament to our collaboration with HPE to optimize financial institution anti-money laundering solutions based on machine learning,” concluded Abhishek Chatterjee, Co-Founder and CEO of Tookitaki with HPE, our systems have a deep understanding of Big Data as a Service and solution design development for rapidly designing and deploying AI solutions.They use a combination of distributed data-parallel architecture and machine learning to increase scalability across layers Ensure across technologies and systems You can benefit from this collaboration by implementing systems with high module accuracy to ensure they stay compliant at a time when organizational growth and business continuity are critical to success. ”

After this successful collaboration with UOB, HPE and Tookitaki are ready to assist other Asia Pacific banks and financial institutions seeking the business benefits of an enhanced AML solution delivered with the flexibility of an as-a-service model.

“By complementing Tookitaki’s regulatory compliance expertise with our data analytics platform and HPE GreenLake as-a-service offering, we can seamlessly deliver real-world AI solutions that deliver business results to our clients of financial institutions across the region can.” said Khai Peng Loh, general manager, Asia-Pacific solution sales for Hewlett Packard Enterprise. “We look forward to helping our customers better manage regulatory risk.”

HPE GreenLake Cloud Services provides customers with a powerful foundation to drive digital transformation through an elastic as-a-service platform that can run on-premise, on the edge, or at a colocation facility. HPE GreenLake combines the simplicity and agility of the cloud with the governance, compliance, and visibility that hybrid IT brings. HPE GreenLake offers a range of cloud services that accelerate innovation, including cloud services for computing, container management, data protection, HPC, machine learning, networking, SAP HANA, storage, VDI and VMs. The HPE GreenLake Cloud Services business is growing rapidly, with a total order value of over $ 4.2 billion and more than 700 partners selling HPE GreenLake. Today, HPE GreenLake has more than 1,000 customers in 50 countries of all industries and sizes, including Fortune 500 companies, government and public organizations, and small and medium-sized businesses. For more information on HPE GreenLake, visit:

About Tookitaki Holding Pte. GmbH.

Tookitaki Holding Pte. Ltd. offers corporate software solutions in the field of anti-money laundering (AML) and reconciliation. Headquartered in Singapore, the startup innovates the $ 100 billion range for regulatory compliance by delivering machine learning solutions that are actionable, scalable, and explainable. In 2020, the company won the Regulation Asia Awards for Excellence, the WITSA Global ICT Excellence Award and the G20TechSprint Accelerator. In 2019, the company was selected as a technology pioneer by the World Economic Forum to recognize its ability to shape the AML industry and the region in new and exciting ways. Tookitaki is backed by institutional investors such as Viola, SIG, Illuminate Financial, Jungle Ventures and Spring Seeds, an investment arm of the Singapore government. visit

About UOB

United Overseas Bank Limited (UOB) is a leading bank in Asia with a global network of more than 500 offices in 19 countries and territories in the Asia-Pacific region, Europe and North America. Since its inception in 1935, UOB has grown organically and through a series of strategic acquisitions. UOB is one of the world’s leading banks: Aa1 from Moody’s Investors Service and AA- from S & P Global Ratings and Fitch Ratings. In Asia, UOB has its headquarters in Singapore and banking subsidiaries in China, Indonesia, Malaysia, Thailand and Vietnam as well as branches and representative offices throughout the region.

In more than eight decades, generations of UOB employees have implemented the entrepreneurial spirit, the focus on long-term value creation and the unwavering commitment to do the right thing for our customers and colleagues.

We believe in being a responsible financial services company and we are committed to improving the lives of our stakeholders and the communities in which we operate. Just as we are committed to helping our clients manage their finances wisely and grow their business, UOB supports social development, especially in the arts, children and education. visit

About HPE

Hewlett Packard Enterprise is the global edge-to-cloud platform-as-a-service company that helps companies accelerate their results by unlocking the value of all their data, everywhere. HPE is based on decades of reshaping the future and innovating to power our lives and work. It offers unique, open and intelligent technology solutions with a consistent experience across all clouds and edges to help customers develop new business models and break new ground and increase operational performance. For more information visit:

1 A suspicious transaction alert can identify a single transaction or a series of related transactions. UOB processes around 30 million transactions in total every month.

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Editorial contact:
Teljya Oka-Pregel, HPE