Earlier this week, Enigma hosted an ACAMS-NY Chapter event, C-AML: Exploring the New Frontier of Crypto-AML. As I engaged with two hundred other compliance professionals, it became abundantly clear that this is an important new frontier for AML. In fact, a small survey of ACAMS New York chapter members revealed that while 75% of our peers anticipate that cryptocurrency will affect their company in the future, only 33% believe they are proficient in cryptocurrency compliance. Much of the evening’s discussion concerned challenges around identifying and connecting relevant data related to cryptocurrency transactions to better manage AML risks.
While we wait for much-needed guidance in this largely uncharted territory, our compliance and financial crime teams are proactively trying to get a handle on how to think about cryptocurrency in the context of their specific programs. One of the biggest unknowns is how and when to incorporate an effective transaction monitoring approach into AML programs. I have to re-iterate a message we’ve often heard: that the answer is truly in the data. You just need to responsibly get at it.