Combatting Crypto Money Laundering
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.
