JMLSG is consulting on a new part to its sectoral guidance, to cover cryptoasset exchange providers and custodian wallet providers.
The new Part 22:
- defines crypto-assets, noting some examples which firms should carefully consider to assess whether they fall within the definition, and explains what “money” is (and this includes electronic money – a cryptoasset is not “money”);
- explains who falls within the definition of a cryptoasset exchange provider and a custodian wallet provider;
- sets out the scope of regulation;
- looks at the key ML risks in the sector;
- suggests measures of risk management and mitigation;
- covers CDD measures, including who the customer is;
- looks at record keeping requirements;
- gives guidance on dealing with suspicious transactions; and
- reminds affected firms that sanctions obligations apply to them as they do to other firms and noting that lists may now include wallet numbers instead of names.
It asks for comment by 18 May.