Crypto and Virtual Asset Compliance

Crypto Compliance Explained

Crypto-assets introduce innovative ways to store and transfer value—but they also create unique risks of money laundering (ML), terrorist financing (TF), and proliferation financing. To address these risks, global standard-setters and regulators—including the European Union, Financial Action Task Force (FATF), and national authorities—now impose strict AML/CFT requirements on crypto-asset service providers (CASPs/VASPs).

These requirements apply to businesses that exchange, safeguard, transfer, or issue crypto-assets. Criminals exploit virtual assets to obscure transaction trails, move illicit proceeds quickly across borders, or circumvent sanctions—making robust AML/CFT controls essential.

How Crypto AML/CFT Works

Crypto AML/CFT frameworks operate by creating transparency, traceability, and oversight in an environment originally designed to be pseudonymous.
They aim to prevent the misuse of virtual assets by:

  • Verifying customer identities,

  • Monitoring transactions,

  • Detecting illicit patterns,

  • Applying the Travel Rule for crypto transfers, and

  • Reporting suspicious transactions to national Financial Intelligence Units (FIUs).

Regulatory regimes require CASPs to treat crypto-asset activities with the same rigor as traditional financial services, in line with the EU’s updated AML Package—which explicitly expands AML obligations to crypto-asset service providers .

The Legal and Regulatory Framework

Crypto AML/CFT obligations are established through several key instruments:

European Union

International (FATF)

  • FATF Recommendation 15 & FATF Virtual Asset Guidance — sets global standards requiring CASPs to implement CDD, Travel Rule compliance, monitoring, sanctions screening, and suspicious activity reporting.

Once enacted, these requirements become legally binding on all CASPs operating within the jurisdiction, including exchanges, custodians, wallet providers, and other virtual asset intermediaries.

Key AML/CFT Controls for Crypto

Crypto-related AML/CFT measures include:

Customer Due Diligence (CDD)

CASPs must identify and verify customers, understand the nature of the relationship, and conduct ongoing monitoring.

Enhanced Due Diligence (EDD)

Applied to high-risk customers, such as PEPs, complex structures, or customers interacting with high-risk jurisdictions.
EU regulation emphasises the ML/TF vulnerabilities of crypto-asset service providers and the risks linked to transactions with self-hosted wallets .

Transaction Monitoring

CASPs analyze on-chain and off-chain activity to detect red flags, including:

  • Rapid movements of value

  • Use of mixers or privacy-enhancing tools

  • High-risk counterparties

  • Cross-chain or cross-border transactions

  • Links to darknet markets, scams, or sanctioned addresses

Sanctions Screening

Screening must cover:

  • Customers

  • Wallet addresses

  • Beneficial owners

  • Counterparties

  • Transactions

Travel Rule Compliance

Crypto transfers must include accurate sender and recipient information, enabling traceability and accountability across the value chain.

Record-Keeping

Transaction data, KYC records, and verification evidence must be stored for legally mandated periods.

Blockchain Analytics

Blockchain analytics tools help CASPs trace:

  • Transaction flows

  • Source and destination of funds

  • Risk exposure to illicit actors

  • Wallet behaviour patterns

  • Links to darknet services, malware, or sanctioned addresses

These tools are essential to fulfilling monitoring and reporting requirements under AMLR and FATF standards.

PEP & High-Risk Customer Screening

As with traditional finance, CASPs must identify:

  • Politically exposed persons (PEPs)

  • Their family members and close associates

  • Customers linked to high-risk sectors or jurisdictions

AML/CFT frameworks require enhanced monitoring and controls when PEPs or high-risk profiles are involved.

Why Understanding Crypto AML/CFT Matters

For compliance professionals, a strong grasp of crypto AML/CFT is vital to prevent:

  • Abuse of crypto platforms for ML/TF

  • Breaches of EU AMLR, TFR, and FATF obligations

  • Regulatory sanctions or licence suspension

  • Reputational damage

  • Exposure to sanctioned entities or high-risk jurisdictions

  • Misuse of innovative technologies for criminal purposes

As EU regulation now explicitly expands AML/CFT obligations to crypto-asset service providers to mitigate evolving risks, understanding and implementing effective controls is essential for operational, legal, and reputational integrity.