国际清算银行-加密资产反洗钱合规方法（英）-2025.8_8页_811kb

Approach to Anti-Money Laundering Compliance for Cryptoassets

The article discusses the evolving challenges of anti-money laundering (AML) compliance in the context of cryptoassets on permissionless public blockchains, such as Bitcoin and Ethereum. AML approaches relying on trusted intermediaries are ineffective for decentralized systems, where blockchain's immutable public record can be harnessed for proactive monitoring.

Key aspects include:

• Decentralized blockchains use consensus mechanisms without intermediaries, making traditional AML methods inadequate.
• Transaction history on blockchains enables tracing and risk assessment for blockchain-based cryptoassets, including stablecoins.
• A proposed AML compliance score system could inform interventions at points of contact with conventional monetary systems ("off-ramps"), such as crypto exchanges or conversion to fiat currency.
• The score ranges from defining "clean" to "tainted" tokens based on provenance and historical transactions, varying by jurisdiction to incorporate local regulations like foreign exchange rules.
• Different stringency levels include strict KYC requirements, intermediate criteria, and denylist interactions, with authority-defined thresholds guiding acceptance.
• This approach could enhance regulatory coverage, promote user diligence, and facilitate international cooperation to close gaps in financial integrity.

Broader implications involve integrating blockchain provenance into AML/anti-money financing terrorism (AML/CFT) efforts, potentially through scoring embedded in token transfers, while balancing incentives and responsibilities among users, exchanges, and authorities.