AML Considerations For The Fintech Industry

The Financial Action Task Force (FATF) recently cautioned that terrorists and other criminals are increasingly using internet-based financial technologies (Fintech) to raise and launder funds for illicit purposes. Areas presenting potential anti-money laundering (AML) and terrorist finance risk include crowdfunding, marketplace lending, virtual currencies, prepaid cards, and other technologies that facilitate the raising, disbursement, and transmittal of funds between end users (often internationally).

While many of these products and services are already subject to direct AML regulation as money services businesses (MSBs), particularly money transmitters, some do not fit neatly within existing AML regulatory frameworks, even though they facilitate financial transactions. Still some businesses may not appreciate the application of the AML laws to their technology or, even if they do, may not have the resources or experience to implement appropriate compliance