AML: Everything to Know

By  Beluga Research August 23, 2023

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  • Cryptocurrency "AML" refers to "anti-money laundering" measures and regulations in place to detect and prevent such activities within the digital currency ecosystem
  • AML regulations were implemented due to the decentralized and pseudonymous nature of cryptocurrencies, aiming to address money laundering and criminal activities
  • Key components of cryptocurrency AML include "Customer Due Diligence" (CDD), transaction monitoring, risk assessment, reporting and compliance
  • Despite numerous advantages of AML measures, there are also concerns regarding privacy, regulatory burden, false positives and potential centralization


Cryptocurrency "AML" refers to "anti-money laundering" measures and regulations in place to detect and prevent such activities within the digital currency ecosystem. Cryptocurrency AML refers to the set of regulations, procedures and technologies aimed at preventing money laundering, terrorist financing and other illicit activities within the realm of cryptocurrencies. AML measures are designed to ensure that cryptocurrencies are not misused for illegal purposes, thus promoting transparency and maintaining the integrity of the financial system.

A Brief History

The need for AML regulations in the cryptocurrency space originally arose due to the decentralized and pseudonymous nature of cryptocurrencies, which presented opportunities for money laundering and criminal activities. In response, regulatory bodies worldwide began to implement measures to address these concerns.

One significant milestone in the history of cryptocurrency AML was the "Financial Action Task Force's" (FATF) guidance in 2019. The FATF, an intergovernmental organization, issued recommendations for "Virtual Asset Service Providers" (VASPs) to comply with AML and "Counter-Terrorism Financing" (CFT) regulations. These recommendations aimed to bring cryptocurrencies within the scope of traditional financial regulations.

AML: Everything to Know

  • Customer Due Diligence (CDD) - "Customer Due Diligence" (CDD) is a crucial aspect of AML procedures. It involves verifying the identity of customers and assessing the potential risks associated with transactions. VASPs are required to implement robust "Know Your Customer" (KYC) procedures to gather relevant information about users.
  • Transaction Monitoring - AML regulations emphasize the importance of continuous transaction monitoring to detect suspicious activities. VASPs employ advanced technologies and algorithms to identify patterns, anomalies and red flags that may indicate illicit behavior. This proactive monitoring helps in preventing money laundering and other illegal activities.
  • Risk Assessment - Conducting a risk assessment is essential for VASPs to understand and evaluate the potential risks associated with customers and transactions. Risk-based approaches enable VASPs to allocate resources effectively and implement appropriate AML measures based on the level of risk involved.
  • Reporting and Compliance - VASPs are legally obligated to report suspicious transactions to the relevant authorities. Compliance with AML regulations requires thorough record-keeping, reporting and cooperation with law enforcement agencies. Non-compliance can result in severe penalties and reputational damage.
  • Blockchain Analysis - Blockchain analysis plays a crucial role in cryptocurrency AML. It involves tracing and analyzing transactions on the blockchain to identify patterns and track the flow of funds. Various tools and techniques are utilized to uncover illicit activities and establish links between addresses and entities involved in suspicious transactions.
  • Regulatory Landscape - The regulatory landscape surrounding cryptocurrency AML is evolving rapidly. Different jurisdictions have implemented varying degrees of regulations, with some countries imposing stricter measures than others. It is important for businesses operating in the cryptocurrency space to stay updated with the legal requirements of the jurisdictions in which they operate.

Getting Started

To understand cryptocurrency AML, it is important to grasp the fundamental characteristics of cryptocurrencies. Unlike traditional financial systems, cryptocurrencies operate on decentralized networks known as "blockchains." Transactions within these networks are recorded on a public ledger, ensuring transparency and immutability. However, the pseudonymous nature of cryptocurrency transactions poses challenges for identifying the individuals behind them.

To combat these challenges, various regulatory measures have been introduced. One of the key requirements is the implementation of KYC procedures by cryptocurrency exchanges and other service providers. KYC involves collecting and verifying user identification information, such as name, address and identification documents, to establish the identity of individuals using cryptocurrency services. This helps to create a link between the real-world identity of users and associated cryptocurrency transactions.

Unique Aspects

Cryptocurrency AML has unique aspects that differentiate it from traditional financial systems. One such aspect is the use of blockchain analytics tools. These tools leverage advanced data analysis techniques to trace and analyze cryptocurrency transactions on the blockchain. By examining transaction patterns, addresses and other data points, these tools can identify suspicious activities and potentially link them to illicit actors.

Another unique aspect is the concept of "mixing services" or "tumblers." These services aim to obfuscate the origin and destination of cryptocurrency transactions by mixing them with other transactions, making it difficult to trace the funds. While mixing services can have legitimate uses for privacy-conscious individuals, they have also been exploited for money laundering purposes. Regulators have been focusing on developing strategies to detect and mitigate the risks associated with these services.

Furthermore, the international nature of cryptocurrencies presents challenges for AML efforts. Cryptocurrencies operate across borders without being bound by traditional financial regulatory frameworks. This has led to the need for international cooperation and coordination among regulatory bodies to effectively combat cross-border money laundering and other financial crimes involving cryptocurrencies.


  • Enhanced Security - AML measures help to enhance the overall security of the cryptocurrency ecosystem by identifying and mitigating risks associated with illicit activities. This protects users and businesses from potential scams, fraud and financial losses.
  • Compliance with Regulations - Implementing AML measures enables cryptocurrency businesses to comply with regulatory requirements imposed by governments and financial authorities. This helps foster trust and legitimacy within the industry, attracting institutional investors and traditional financial institutions.
  • Deterrence of Criminal Activities - AML practices act as a deterrent for criminals who may attempt to exploit cryptocurrencies for money laundering or other illicit purposes. The risk of being detected and facing legal consequences discourages such activities, making it more challenging for criminals to use cryptocurrencies as a tool for illicit transactions.
  • Improved Transparency - AML procedures promote transparency by requiring cryptocurrency service providers to collect and verify user identification information. This helps create an auditable trail of transactions, making it easier to trace and investigate suspicious activities. Additionally, increased transparency can contribute to the overall reputation and acceptance of cryptocurrencies in mainstream finance.
  • Collaboration with Law Enforcement - AML practices facilitate collaboration between cryptocurrency businesses and law enforcement agencies. By reporting suspicious activities and sharing information, cryptocurrency service providers can assist in investigations and help combat financial crimes. This collaboration strengthens the legitimacy of cryptocurrencies and aids in building a cooperative relationship between the industry and regulatory authorities.


  • Privacy Concerns - AML measures may compromise the privacy of cryptocurrency users. The requirement to disclose personal information and undergo identity verification procedures can raise concerns about data security and the potential misuse of sensitive information. Striking a balance between privacy and AML requirements is a challenge with which the industry continues to grapple.
  • Regulatory Burden - Implementing and complying with AML regulations can be burdensome for cryptocurrency businesses, especially smaller startups. The costs associated with establishing robust AML systems and conducting ongoing monitoring and reporting can strain resources and hinder innovation within the industry.
  • False Positives and Compliance Challenges - AML systems may generate false positives, flagging legitimate transactions as suspicious. This can lead to delays, account freezes or even wrongful account closures, creating inconvenience and frustration for users. Additionally, navigating the complex and evolving regulatory landscape poses compliance challenges for businesses, requiring continuous adaptation to new guidelines and standards.
  • Potential for Centralization - AML measures can contribute to the centralization of cryptocurrency transactions and services, as compliance becomes more demanding and resource-intensive. This contradicts the decentralized nature of cryptocurrencies and raises concerns about the concentration of power and control in the hands of a few entities.
  • Effectiveness Limitations - While AML measures are crucial in combating illicit activities, they are not foolproof. Determined criminals can still find ways to circumvent AML controls, such as using privacy-focused cryptocurrencies or decentralized exchanges. Therefore, it is important to recognize that AML measures have limitations and should be complemented with other security and investigative techniques.