Crypto Currency

AML Directive and Crypto Currency

The 5th anti-money laundering (AML) directive (since May 2018) stipulates even more requirements in relation to crypto currencies. But things change quickly in the crypto world and it takes time for regulators to catch up. Often, sizeable financial institutions are slow-moving, therefore a strong but flexible policy and procedures should be designed for easy adaptation to changes.

In the 5th, but even more so in the 6th AML Directive, requirements relating to licences for FinTechs (financial technology), wallet suppliers and crypto companies have been elaborated on further still.

In the Dutch Money Laundering and Terrorist Financing (Prevention) Act (WWFT) a mandatory registration of crypto service providers (CSP) i.e. firms offering services for the exchange between virtual and regular currencies, and providers of custodian wallets for virtual currencies, must apply to the (local) regulator for registration.

Wide range of crypto currencies

Besides the crypto currencies described and mentioned in the AML directive, there are always new combination on the horizon. They appear faster than the regulator can handle them, which is why newer ‘currencies’ must be analysed. Is it a currency or not? But crypto currencies can also take on a different form, such as tokens, equity tokens, utility tokens, swaps and security tokens.

Crypto policy for financial institutions and FinTechs

To ensure compliance with regulations, a solid fundamental systematic integrity risk analysis (SIRA) and a strong but flexible policy and procedures should be produced. BlueMonks has experience with a wide range of financial institutions and increasingly with FinTechs and crypto service providers. We can help you to create this foundation, to ensure compliancy with relevant regulations.

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  • Develop custom-made crypto policies for financial institutions

  • Support crypto service providers with regulatory registration

  • Perform crypto-specific integrity risk analyses

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