On 19 March, Cipher Trace published a summary of the draft guidance issued by FATF, which included such things as, VASP should begin to assess and mitigate proliferation financing (PF) risks (with FATF currently developing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.

If you would like to make a modest contribution for my time and ongoing expenses, I have a page, where contributions start as low as $3, 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

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: