Problems in the Revised FATF Standard 1


Bethany Walsh

Sep 08, 2021

(1) Definition of virtual assets and VASP

The revised FATF Standard introduces new terms "virtual asset" and "virtual asset service provider". If an emerging asset is classified as a traditional financial asset according to the standard but relies on "virtual asset" at the technical level, it is still unclear how each jurisdiction should classify it. Besides, regions believe that the scope covered by the definition of VASP should be further explained to ensure the general consistency of the definition of VASP, which is very important for the applicable standards of operators and service providers in the jurisdiction.

(2) Peer to peer transactions and private / non-public wallets

At present, without the participation of VASP or financial institutions, the peer-to-peer transactions of virtual assets are not clearly subject to the anti-money laundering obligations under the revised FATF Standard. Since the revised FATF Standard focuses on placing anti-money laundering obligations on intermediaries between individuals and the financial system, there is no clear provision for such virtual asset transactions. However, there is not enough evidence to show that the number and value of anonymous peer-to-peer transactions have changed greatly since June 2019.

At the same time, the introduction of new virtual assets may greatly enhance the risk of money laundering / terrorist financing, especially when virtual assets are widely used for peer-to-peer anonymous transactions. When countries believe that the risk of money laundering / terrorist financing is too high, they can take measures such as unsecured wallet transfer, limit the number of transactions, or force the use of VASP or financial institutions to reduce the risk. But so far there is no consistent international practice.


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