Navigating AML for cross-border payments with new virtual asset regulations
Seeing a lot of talk about how the FATF's updated guidance on virtual assets is impacting traditional cross-border payment providers who might touch crypto at some point, even indirectly. The travel rule implementation is one thing, but how are firms really managing the risk of commingled funds or transactions that pass through unhosted wallets? It feels like the regulatory net is widening significantly, requiring more robust transaction monitoring even for what were previously considered 'low-risk' corridors. What are others seeing as the primary compliance challenges here, especially with the varying jurisdictional approaches?
That's a critical point. The commingled funds issue, especially when dealing with nested services or mixers, seems incredibly challenging to untangle for AML purposes. How are institutions currently approaching the 'look-through' requirement for these types of transactions without completely halting service?