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This Guidance seeks to explain the application of the risk-based approach to AML/CFT measures in the VC context; identify the entities involved in VCPPS; and clarify the application of the relevant FATF Recommendations to convertible virtual currency exchangers. This Guidance is also intended to help national authorities understand and potentially develop regulatory responses, including the need to amend their national laws in order to address the ML/TF risk of VCPPS. Furthermore, this Guidance provides clarity to help the private sector better understand the relevant AML/CFT obligations and how they can effectively comply with relevant requirements, by i) showing how specific FATF Recommendations should apply to convertible virtual currency exchangers and ii) identifying obstacles to applying mitigating measures rooted in VCPP’s technology, business models and/or legacy legal frameworks.