Did you know that despite the market capitalization of cryptocurrency peaking at $3 trillion it continues to surpass over $1 billion daily? With such volatility, growth, and potential, money laundering and terrorist financing mirror the same risks as the traditional regulated entity space.
In this blog, we will explore the intricate landscape of regulations as it applies to cryptocurrencies, the critical issue of sanctions compliance in the cryptocurrency space, and how KYC2020’s DecisionIQ, with the power of AI and collaborative intelligence, is transforming the way regulated entities benefit from these advancements while maintaining the importance of auditability and transparency over opaque solutions and systems.
The Crypto Conundrum: Money Laundering and Terrorist Financing
As the cryptocurrency industry becomes more ubiquitous in the financial systems, it faces similar challenges to traditional financial systems in combating money laundering and terrorist financing. Terrorists and criminal organizations seek to exploit the pseudonymous nature of cryptocurrencies to disguise the illicit origins or destination of their funds. By doing so, they are attempting to evade law enforcement to fund further criminal activities, while leaving a trail of damage in their wake.
Anti-Money Laundering (AML)/Counter Terrorist Financing (CTF) measures have been in place in traditional finance for some time now to help detect, deter, and in some cases prevent financial crimes from happening. While it is estimated that only 5-10% of ML/TF is actually detected, regulators worldwide have issued comprehensive guidelines and directives to at least try to make a dent. The rapid growth of the crypto industry has outpaced these efforts and is creating opportunities for criminals to exploit the regulatory gaps while they play catchup. The complexity of crypto, as it relates to AML/CTF regulations, has made it challenging for cryptocurrency exchanges to comply with new and ever-expanding regulations.
The Rising Tide of Regulatory Obligations
Many custodial and non-custodial Virtual Asset Services Providers (VASPs) are subject to Know Your Customer (KYC) obligations. Among the primary aspects of dealing with cryptocurrency is to put in place transaction monitoring, adherence to the Travel Rule, and screening for sanctions, PEP and Adverse Media on persons and entities who are involved in those transactions. Failure to perform these and other functions that are required by AML/CTF regulations exposes these businesses to significant reputational risk, civil penalties and criminal charges that could lead to prison.
The FATF and the Future of Crypto Regulation
The Financial Action Task Force (FATF) provided clarity related to AML/CTF regulations in its “Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers”. It makes recommendations on how countries, regulators, and virtual asset service providers should manage ML/TF risks related to dealing in cryptocurrencies. This guidance promotes a risk-based approach, similar to that of traditional regulated entities including those that would be most affected like financial institutions and MSBs. It is the member countries’ responsibility to implement the recommendations to ensure that there are safeguards against widespread abuse in the use of cryptocurrencies in ML/TF related crimes.
KYC for Crypto Companies
A strong AML/CTF compliance program, rooted in a risk-based approach, is essential to align with the FATF recommendation and country-specific regulations. Customer screening and monitoring, understanding the customer’s financial activities and source of funds/wealth, assessing risk and compliance with the Travel Rule, are all key aspects in preventing, detecting and deterring ML/TF offences in financial systems. The role of a qualified compliance officer is pivotal in maintaining the integrity of a cryptocurrency exchange’s compliance efforts. Any lapses in compliance could result in severe fines and penalties, underscoring the importance of rigorous compliance in cryptocurrency exchanges.
To onboard and engage with high-risk customers, businesses must implement Customer Due Diligence (CDD) procedures as of their AML compliance regime. CDD procedures include screening against watchlists including sanctions, regulatory, criminal, and negative news. For businesses that deal with crypto transactions, this is not enough.
OFAC has expanded its purview by incorporating digital currency addresses into the SDN List, aiming to notify the public about specific digital currency identifiers linked to blocked individuals. Originally, the incorporation of cryptocurrency addresses into these due diligence processes was observed during the Silk Road crackdown and in the context of Darknet markets like Hydra and AlphaBay, as well as mixer services such as TornadoCash and Blender. More recently, we’ve seen the inclusion of Digital Currency Addresses related to the terrorist group Hamas in OFAC’s SDN and other watchlists.
Following this development, it is imperative that businesses implement rigorous screening processes for digital currency addresses. This is necessary to guarantee that they do not engage in transactions or trade involving digital currency identifiers associated with a blocked person.
In Conclusion: Screening for Cryptocurrency addresses with DecisionIQ
The importance of robust compliance solutions that include cryptocurrency address screening for sanctions and other related ML/TF exposure has never been greater. KYC2020, with its innovative DecisionIQ, all-in-one Sanctions, PEP & Adverse Media Screening platform, is aimed at transforming the way VASPs, DeFi, and blockchain innovators meet their regulatory obligations.
Businesses need more than just a compliance screening tool; they need a partner that understands the nuances of cryptocurrency compliance as it relates to sanctions.
DecisionIQ combines the power of AI and collaborative intelligence to significantly reduce false positives, provide transparency in the results, and ultimately demonstrate to the regulator or examiner that all steps have been taken to reduce the risk of dealing with a person or entity on a sanctions list. DecisionIQ ensures that every screening decision is recorded and auditable, similar to the blockchain concept of transparency through “proof of work”, or in our case, what we call a “proof of decision”.
KYC2020’s AI-driven technology with collaborative intelligence empowers those dealing with cryptocurrencies to maintain a rigorous compliance program without compromising on quality or incurring unnecessary costs.
“A compelling part of the technology is that it provides a proof of decision for every screening decision. Unlike other ‘black-box’ AI solutions, KYC2020 approach is similar to the blockchain concept of transparency via ‘proof of work.'” – Coinchange
Click here to read the full Coinchange Case Study and discover how DecisionIQ transformed their screening efforts related to compliance by reducing the cost and manual effort in dealing with false positives and bad data.
Verifiable Auditability: DecisionIQ’s “Proof of Decision” approach aligns with blockchain principles of transparency. It provides a verifiable audit trail for every screening decision and reviewer action. Unlike other ‘black-box’ AI solutions, DecisionIQ ensures clarity and transparency through its ‘proof of work.’
Reduce False Positives: False positives can be a significant challenge in compliance. DecisionIQ uses high quality and structured data and a screening decision system with auto-clearing capabilities to deliver one of the lowest false positive rates in the industry, saving your business time and resources while ensuring that legitimate customers are not held up in unnecessary reviews.
Faster Onboarding: Speed is of the essence in the crypto world. DecisionIQ’s rapid screening processes ensure faster onboarding, allowing regulated entities to provide a seamless experience to their customers.
Rapid Review and Clearing System: KYC2020’s Rapid Review and Clearing System (aka RABBIT) is the solution to the slowdown caused by case management systems that are not ‘human factored’ for large volume reviews. RABBIT is equipped with built-in functions for visualizing and processing information on a large scale, making it a more efficient and effective bulk review process over the traditional methods deployed by many others.
Watchdog‘s Automated Clearing Technology: We further improved DecisionIQ’s capability to handle edge cases in AI that result in false positives. Watchdog’s tech stack is designed around Collaborative Intelligence (CI), and it includes a hit pattern recognition system, Contextual AI to predict gender and nationality of names, and a proprietary name relevancy scoring system that is more effective and intuitive than fuzzy scoring. This additional intelligence is used as part of a rule-based system to lower the rate of false positives caused by borderline cases that humans can detect better than AI. Watchdog is also supported by a clear proof of work for verifiable auditability.
DecisionIQ offers a range of features designed to meet the unique needs of the crypto industry, ensuring compliance is not a burden but a competitive advantage. With DecisionIQ, crypto companies can focus on what they do best – innovating and providing value to their customers – while leaving the complexities of compliance in capable hands.
Remember, you don’t have to compromise on quality and compliance while lowering costs. DecisionIQ is here to make AML compliance a seamless and efficient journey. Stay ahead in the crypto compliance landscape with KYC2020.