On AML and crypto exchanges, specifically for US users operating abroad

asked by u/takin25395511 · 13d · 1 answers

I'm still trying to get my head around the nuances of AML compliance when it comes to crypto exchanges and US citizens. If a US citizen is living abroad, say in Europe, and uses a non-US crypto exchange that doesn't have a FinCEN registration, but does comply with local EU AML/KYC standards, are there still significant US compliance risks for the exchange? My understanding is that the FATF recommendations are fairly global, but the US still has its own specific interpretations and extraterritorial reach. I'm wondering if any of you have practical experience or insights into how these exchanges navigate the potential for attracting US persons without direct US regulatory entanglement. Is it purely about IP blocking, or is there more to it?

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  • u/kwame_mensah· 1 pts· 13d

    That's a good question and touches on a complex area. While the exchange might satisfy local EU regulations, the extraterritorial reach of US AML laws, particularly if the user is a US person, is where the significant risk for the exchange could still lie, regardless of FinCEN registration. It often comes down to the exchange's risk assessment and appetite for dealing with US persons.

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