KYC/AML Obligations for Virtual Currency Service Providers
Starting 10 January 2020, virtual currency service providers will be subject to the same know-your-customer and anti-money laundering obligations as credit and financial institutions. This webpage addresses frequently asked questions regarding virtual currency service providers and provides further resources for those interested in gaining a more detailed understanding of the law. If you have any questions or need legal advice, please contact us.
FAQs for virtual currency service providers
Where can I find additional resources about my KYC/AML obligations?
The following resources provide additional insight on the KYC/AML obligations applicable to virtual currency service providers starting 10 January 2020. For more detailed information and legal advice, please contact us.
Legal Texts
- Financial Markets Anti-Money Laundering Act (FM-GwG)
- FM-GwG Amendments (excerpted version)
- 5th Anti-Money Laundering Directive (Directive (EU) 2018/843)
- FMA Online Identification Regulation (Online-IDV)
- FATF Guidance for a Risk-Based Approach for Virtual Assets and Virtual Asset Service Providers
Articles
- Oliver Völkel, On the term "virtual currency"
- Leyla Farahmandnia & Bryan Hollmann, Amendments to the Financial Markets Anti-Money Laundering Act (FM-GwG) and Applicability to Crypto Companies
- Oliver Völkel, Gegen Geldwäsche und Terrorismus: Neue Regeln für die Krypto-Branche, der brutkasten, 4 July 2019