On 28th June, Elliptic published its analysis of new guidance that updates the 2015 FATF guidance, providing clarity on the role of transaction monitoring solutions for AML/CFT risk management for virtual assets and virtual asset service providers.  The analysis contains key takeaways on –

  • the importance of transaction monitoring solutions;
  • the importance of conducting a firm-wide risk assessment;
  • the global requirement to implement FATF Recommendation 16 (the “Travel Rule”);
  • the application of the FATF standards to a wide range of product and service providers;
  • the importance of address blacklisting and typologies development; and
  • the need for banks to develop a risk-based approach to virtual assets.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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