Combatting Crypto Money Laundering
An interview with Alex Zerden
Criminal actors looking for new ways to launder money are increasingly turning to cryptocurrency as a way to inject their ill-gotten gains into the legitimate financial system, to obfuscate the sources of their funds and convert it to cash or other assets. As criminals turn to novel ways to launder money, regulators and law enforcement are responding in like, enacting new and clarifying existing laws and employing increasingly sophisticated investigative and enforcement tools. Alex Zerden, the founder of Capitol Peak Strategies and a former Treasury Department official, discusses some of the high-profile instances of illicit uses of cryptocurrency and how digital assets may be used for money laundering and other criminal activities. Misconceptions abound about the proliferation and utility of digital assets for money laundering and the lawlessness of the crypto industry overall. Alex makes the case that certain key attributes of cryptocurrency may not make them the most elegant tool for such purposes. He explains the anti-money laundering (AML) regulatory framework, FinCEN guidance, and sanctions obligations that apply to the crypto industry and recent DOJ and FinCEN AML enforcement efforts.
About Alex Zerden
Alex Zerden is the founder and principal of Capitol Peak Strategies, a FinTech, digital asset, and emerging technologies advisory firm. He is an adjunct senior fellow at the Center for a New American Security and a Term Member of the Council on Foreign Relations. As a regulatory lawyer, economic policymaker, and financial diplomat, Alex brings fifteen years of public and private sector experience at the intersection of financial services, national security, and law with a focus on financial regulation, anti-money laundering and countering the financing of terrorism (AML/CFT), economic sanctions, anti-corruption, financial enforcement and oversight investigations, economic crisis response, and public-private partnerships. Alex began his career representing U.S. and international victims of terrorism. He has worked across the U.S. government to protect the financial system from abuse and promote economic growth, including at the Treasury Department, Financial Crimes Enforcement Network (FinCEN), White House National Economic Council, House of Representatives, and Senate. From 2018-2019, Alex deployed to Afghanistan to lead the Treasury Department office at the U.S. Embassy in Kabul. Alex has published extensively on issues involving AML/CFT, economic sanctions, anti-corruption, cybersecurity, and FinTech.
