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Cryptocurrency Compliance: An AML Perspective - …

Cryptocurrency compliance : An AML Perspective Authored By: Sherri Scott 2 | P a g e Table of Contents Executive Summary 3 Blockchain for Blockheads 3 RegTech 5 Sanctions 7 Transaction Monitoring 7 Exponential Growth 7 How to Audit FIs Servicing the Cryptocurrency Industry 8 Conclusion - Unity in the Financial Intelligence Community 10 Exhibit A: The Association of Accounting Technicians (AAT) 11 Reference Document Exhibit : Bitcoin Reference Guide 12 Exhibit C: Money Service business (MSB) compliance Checklist 13 Exhibit D: Currency Crimes - Federal Money Laundering Laws 15 Exhibit E: Examination Procedures 16 3 | P a g e Executive Summary October 31, 2017, marks the 9th anniversary of Bitcoin s introduction to the world, and there is yet a consensus to be made on how to regulate the Cryptocurrency industry.

4 | P a g e Virtual currency exchanges manage virtual wallet accounts and are responsible for obtaining customer information and performing due diligence to the same standard of expectation required by any money services business (MSB).

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