The Chamber recognizes that, like any industry and any currency, these technologies can be used for incredibly important purposes; but also, in some cases, to engage in unlawful activity.

Compliance with AML obligations is of utmost importance to virtual currency-related businesses. Those whose activities trigger AML compliance programs and associated record keeping and reporting requirements have and will continue to vigorously maintain the appropriate programs to deter illicit activity from entering their platforms.

Both the Financial Crimes Enforcement Network (FinCEN), the U.S. agency overseeing the Bank Secrecy Act (BSA), and the Financial Action Task Force (FATF), a multi-governmental organization that sets standards and promotes global implementation of legal, regulatory, and operational measures for AML/CFT, have actively engaged in this area. Most recently FinCEN published guidance in May, 2019, and the FATF amended its Recommendations to include “virtual assets” and “virtual asset service providers” (VASPs) and later interpreted its Recommendation to include them within the context of its Wire Transfer framework under the “Funds Transfer Rule” and “Funds Travel Rule.” This means VASPs must:

“… obtain and hold required and accurate originator [sender] information and required beneficiary [recipient] information and submit the information to beneficiary institutions … if any. Further, countries should ensure that beneficiary institutions … obtain and hold required (not necessarily accurate) originator information and required and accurate beneficiary information …” (FATF Recommendations 2012, as amended June 2019)

Compliance with the new FATF recommendations requires many key institutions in the virtual asset industry, most notably exchanges, to institute new procedures and systems by June 2020.


Participate both at the international level with the FATF process and the OECD plenary meetings in Vienna as well as engage at the national level with FinCEN and Members of Congress to educate, inform, and advocate on issues rising at the intersection of blockchain technology and AML compliance.


Co-founded the Blockchain Alliance, a public-private forum created to make the blockchain ecosystem more secure and to promote further development of this transformative technology.

Developed and regularly holds meetings of its AML Task Force to discuss regulatory developments.

Participated in the FATF process by engaging in the OECD plenary meetings in Vienna as well as submitting a comment letter.

Educated policymakers, including holding briefings for lawmakers on Capitol Hill.

Actively engages on AML legislation focused on the virtual currency industry, preventing deviations from established FinCEN and industry practice. One such example of these efforts is submitting our Statement for the Record on S. 1241 and working with Members of Congress to ensure that language that would have changed the way in which virtual currency exchanges and administrators are regulated is removed.

Submitted comments to FinCEN on its May 2019 Guidance and the Funds Travel and Transfer Rules, and discussed these with FinCEN officials to enable a better, more proactive compliance environment.