I spent a little time over the break thinking about what’s happening with anti money-laundering (AML) and counter terrorism-financing (CTF) regulation, since it had come time to update the Technological Considerations of AML/CTF Programs published by LexisNexis as part of their Anti-Money Laundering and Financial Crime publication. (There’s a blurb for my part embedded below.)
The interesting shift in this version is that growth of AML/CTF regulation for complementary currencies (ie. currencies that are not backed by a government). Organised crime groups are finding all sorts of creative ways to use complementary currencies to launder money, including the creation of bitcoin ‘mixers’ that are intended to improve anonymity for bitcoin transactions.
A side effect of this regulation – which is largely targeted at bitcoin but which is been written in a way to bring all complimentary currencies under regulation – is that the points-based loyalty programme that you were thinking about introducing might actually bring you under the AML/CTF regulator’s watchful eye. Something as ambitious as Facebook Credits definitely would.
This has all sorts of interesting implications for enterprise-wide governance, but that’s a different discussion since it’s well beyond the scope of the Technological Considerations of AML/CTF Programs piece.
If you’re interested then head over to LexisNexis (or we can catch up for a coffee if you like).
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Image source: Mike Cauldwell
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