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However, many stakeholders, including regulators, compliance professionals and law enforcement, still do not understand cryptocurrency or its anti-money laundering AML impact. That needs to change as cryptocurrency adoption continues to grow. As such, it is essential for those in the AML world to understand this emerging asset class, the risks it introduces and how to mitigate those risks.

Cryptocurrencies are digital assets commonly used as mediums of exchange or stores of value. Cryptocurrency users store funds and carry out transactions using cryptocurrency wallets, which can come in both software and hardware form. Wallets contain two types of cryptographic keys, which are long, unique combinations of letters and numbers necessary to initiate transactions, similar to a password.

Figure 1 below shows some of the ways in which crypto currencies can be used. Each of these use cases and their associated services and organizations have their own risk of exposure to illicit activity. It is important to note that these risk levels only represent the services themselves and are not enough on their own to assess the risk level of a specific entity.

The only way to do that is to analyze each cryptocurrency transaction and counterparties for each entity or service in greater detail see Figure 2 below. Services such as hosted wallets and merchant services, which are used less often for illicit activity, pose a lower risk, whereas terrorist financing schemes are illegal under any circumstances and severely risky.

Those in the middle are not universally considered illegal but are often linked to or used to aid in criminal activities. For example, while gambling is perfectly legal in many jurisdictions, it has also historically been used as a means of money laundering. Cryptocurrency is in fact pseudonymous rather than anonymous. Each circle within the wallets represents a unique cryptocurrency address with its own balance and transaction history.

In this way, cryptocurrency transactions are actually more transparent than ordinary financial transactions. Once recorded on the blockchain, records of transactions stay there permanently and can be viewed at any time, even years later. However, what is not immediately visible on the blockchain is the real-world name of the individual or entity conducting a transaction. Does that make cryptocurrency anonymous? No, but it does mean there are further steps to be taken to determine who is behind a suspicious cryptocurrency transaction.

Furthermore, in most jurisdictions, cryptocurrency services are regulated similarly to financial institutions FIs , 2 meaning know your customer KYC information must be collected and checked and suspicious activity must be reported.

This allows for the identification of the individual service where a user is conducting a suspicious transaction. Based on available data, blockchain analysis shows that just 0. As a result, cryptocurrency is increasingly playing a role in nearly every type of criminal activity that matters to AML professionals.

This should not be surprising. Criminals have always been early adopters of technology and cryptocurrency is no exception. Intended to help both financial authorities and cryptocurrency wallet and exchange firms develop and implement their AML programs, the report set out the following virtual asset red flag indicators of money laundering activity: Transaction Type Transaction Pattern Anonymity Senders and Recipients Source of Funds Geographical Risks Transaction Types While cryptocurrencies represent a new frontier on the money laundering landscape, traditional criminal strategies remain relevant.

FATF found that the following types of transactional behavior, involving conventional means of payment, often indicated an attempt to launder money: Structuring cryptocurrency transactions in small amounts to avoid reporting thresholds. Making a series of high-value cryptocurrency transactions in a short period of time. Immediately transferring cryptocurrency deposits to a service provider in a low regulation jurisdiction.

Immediately withdrawing cryptocurrency deposits with no transaction activity or converting deposits to multiple types of cryptocurrency while incurring fees. Depositing into cryptocurrency wallets with funds that have been identified as stolen. Transaction Patterns In some cases, patterns of unusual cryptocurrency transactions may indicate that money laundering is taking place.

New accounts funded with a large initial deposit that is then traded or withdrawn in its entirety on that same day or shortly thereafter. Transactions involving multiple cryptocurrencies or multiple accounts with no logical business explanation.

Frequent transfers of large amounts of crypto within a set period of time day, week, month to the same account from more than one person. Incoming small-amount transactions from unrelated wallets that are immediately transferred to another wallet or withdrawn for fiat currency. Multiple crypto exchanges carried out at a potential loss as a result of commission fees.

Frequent conversions of large amounts of fiat currency into a cryptocurrency with no logical business explanation. Anonymity The technology that secures cryptocurrency wallets and exchanges against threats also increases the anonymity of customers using the services to trade and hinders oversight from authorities. Money laundering that exploits the anonymity associated with cryptocurrency services may exhibit the following red flags: Transactions involving more than one type of cryptocurrency, and especially cryptocurrencies offering high levels of anonymity, that incur additional fees.

A customer moving their funds from a transparent public blockchain to a centralized cryptocurrency exchange, and then immediately trading those funds for an AEC or privacy coin. Customers that operate as unlicensed service providers for other users on unlicensed peer-to-peer P2P cryptocurrency exchange sites.

An unusual volume or frequency of transactional activity involving P2P platforms or platforms that use mixing and tumbling services with no logical business explanation. Funds deposited into a cryptocurrency wallet from a suspicious source, such as darknet marketplaces, gambling sites or other illegal sites. Users entering a cryptocurrency exchange from IP addresses associated with suspicious sources or conducting transactions with partners using encryption software.

The use of decentralized and unhosted hardware or offline paper wallets to transport cryptocurrency funds across international borders. The use of proxies or domain name registrars DNS that allow users to conceal their domain names when registering for a cryptocurrency exchange. Multiple cryptocurrency wallets controlled from the same IP address. The use of undocumented cryptocurrencies that have been linked to fraud or Ponzi schemes. Funds sent or received by cryptocurrency exchanges with demonstrably inadequate customer due diligence CDD or know-your-customer KYC procedures.

The use of cryptocurrency ATMs or kiosks to facilitate multiple small transactions, or that are in particularly high-risk jurisdictions. Transactions that originate from untrustworthy or suspicious IP addresses or high-risk jurisdictions.

Corporate customers that have internet domain registrations in high-risk jurisdictions or in different jurisdictions than their country of establishment. Senders and recipients that lack knowledge of the source of their transactions or their relationship with their counterparties. Customer profiles: Customers using identification credentials shared by another account or associated with illegal activity. Discrepancies between customer account IP addresses and the IP addresses of initiated transactions.

Customers that frequently change their identification or contact information, such as email and IP addresses. The same customer attempting to access a cryptocurrency platform using different IP addresses in a single day. Customers that regularly make significant profits or losses by transacting with the same subset of individuals. Customers that communicate with other customers in a manner indicative of using their transactions to support illegal activity. Money mule behaviors: Senders that are unfamiliar with cryptocurrency technology.

Elderly or financially vulnerable customers engaging in high-volume cryptocurrency transactions. Customers that purchase large amounts of cryptocurrency in a manner inconsistent with their financial profile. Transactions involving cryptocurrency accounts with known links to illegal activities, such as fraud, extortion, ransomware or darknet marketplaces, or transactions to or from online gambling sites. A single cryptocurrency wallet linked to multiple credit or debit cards that are used to withdraw large amounts of fiat currency.

Higher than normal deposits into cryptocurrency wallets that are then immediately withdrawn as fiat currency.