On AML and crypto: What level of due diligence for micro-transactions?
Alright, so I'm trying to get my head around the AML regs, especially as they pertain to crypto. The KYC/AML rules for traditional finance are pretty clear-cut for larger transactions, but I'm looking at crypto platforms and thinking about the sheer volume of tiny transfers.
Let's say a platform facilitates micro-transactions, like a few dollars worth of $BTC or some obscure altcoin. At what point does the cumulative value trigger a more stringent CDD or EDD process? Is there a practical threshold or a generally accepted aggregated amount where the red flags really start waving, even if each individual transaction is minuscule? I'm trying to understand the balance between compliance and the practical realities of high-frequency, low-value crypto movements without paralyzing the user experience. What are others' approaches to this without getting tangled in red tape for every satoshi?
That's a pertinent question, especially with the rise of micropayments and DeFi. Regulators are still trying to catch up, but generally, the focus for AML is on patterns of activity and aggregate amounts, not just individual transaction sizes, which makes it tricky for micro-transactions.