ANALYSIS: PROPOSED FATF GUIDANCE FOR VIRTUAL ASSETS AND VASP

On 19 March, Cipher Trace published a summary of the draft guidance issued by FATF, which included such things as, VASP should begin to assess and mitigate proliferation financing (PF) risks (with FATF currently developing separate guidance to clarify these requirements), and that transactions to/from non-obliged entities (e.g. unhosted wallets) and transactions where, at an earlier stage, P2P transactions have occurred should be considered higher-risk.

https://ciphertrace.com/analysis-proposed-fatf-guidance-for-virtual-assets-and-vasps

https://www.fatf-gafi.org/publications/fatfrecommendations/documents/public-consultation-guidance-vasp.html

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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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