AML
Non-Hyped Look at FATF Announcement of June 2019 with Respect to Crypto Compliance
First important point – FATF guidelines are NOT for companies or businesses or private sector, they target national authorities of FATF member countries. Which means, until FATF recommendations are implemented into the national law, they are not binding. So – What Needs to Change in the National Legislation? VASPs Read more…
AML
Regulated or Non-Regulated? That is the Question
It is not uncommon to see regulatory requests for cryptocurrency-focused businesses to split activities into 2 parts: regulated and non-regulated. For example, the licensed (e.g. regulated) entity may be dedicated to operations with fiat funds and fiat deposits, and non-regulated entity would be facilitating transactions with cryptocurrencies or managing Read more…
Crypto
Unfortunate Hype About Luxembourg Blockchain Act
It’s been reported recently by a number of news outlets (here or here) that Luxembourg introduced a new Blockchain law. Why I refer to it as an “unfortunate hype” is because, factually speaking, this regulatory statement did not introduce any significant changes and did not really provide Read more…
AML
My Transaction Monitoring is Becoming Too Expensive – How to Optimize?
Many startup founders ask me how to optimize the cost of transaction monitoring or blockchain tracking. Is it really necessary to send all transaction for monitoring and all blockchain transactions for risk-scoring? No! You can be selective and apply a risk-based approach 🙂 It might indeed be very costly to Read more…
Crypto
ICOs for Dummies
Disclaimer (i wrote this post in summer 2017, and it’s surprising that it is still very much valid 🙂 ) After a few recent conference speeches and meetup appearances, it became clear to me that ICO hype continues; and continues to be surrounded by equally impressive volume of city-legends and Read more…
Crypto
Token Functionalities and Their Regulatory Implications
Tokens are used by their issuers to govern and control their business models and help users interact with the platform. However, different token rights, roles or features have different regulatory implications. What are they? Here is a (very simplified) summary of token functions Token Roles and Rights Categorization Business Implications Read more…
AML
KYC for ICO
The majority of ICOs that happened earlier in 2018 and in 2017 did not use any KYC tools, and had no idea who their participants were (here we don’t count ICO pre-sales and private sales, where ICO organizers obviously had personal contacts with early contributors and knew them well). This Read more…