加密资产反洗钱合规方法（英）

Anapproach to anti-money launderingcompliance for cryptoassets Iñaki Aldasoro, Jon Frost,Sang Hyuk Lim, Fernando Perez-Cruzand Hyun Song Shin 13 August 2025 BIS Bulletins are written by staff members of the Bank for International Settlements, and from time to timeby other economists, and are published by the Bank. The papers are on subjects of topical interest and aretechnical in character. The views expressed in them are those of their authors and not necessarily the viewsof the BIS. The authors are grateful to Rebeca Anguren, Raphael Auer, Maha El Dimachki, Marc Farag,Pablo Hernández de Cos, Friedrich Klinger, Ulf Lewrick, Noel Reynolds, Peter Wierts and Phil Wooldridgefor helpful comments and suggestions, Giulio Cornellifor excellent research assistance, Emma Claggettfor editorial review and Nicola Faessler and Danielle Ritzema for administrative support. The editor of the BIS Bulletin series is Hyun Song Shin. This publication is available on the BIS website (www.bis.org). ©Bank for International Settlements 2025. All rights reserved. Brief excerpts may be reproduced ortranslated provided the source is stated. An approach to anti-money laundering compliance for cryptoassets Key takeaways •Existing anti-money laundering (AML) approaches relying on trusted intermediaries have limitedeffectiveness with decentralised record-keeping in permissionless public blockchains.•The public transaction history on blockchains can enable AML and other compliance efforts, such asFX regulations, by leveraging the provenance and history of any particular unit or balance of acryptoasset, including stablecoins.•An AML compliance score based on the likelihood that a particular cryptoasset unit or balance islinked with illicit activity may be referenced at points of contact with the banking system (“off-ramps”),preventing inflows of the proceeds of illicit activity and supporting a culture of “duty of care” amongcrypto market participants. Cryptoassets circulating on permissionless public blockchains have grown in heft rapidly and are becomingincreasingly integrated with the mainstream financial system. As their usage expands, concerns about illicitactivity have also grown. Since 2022, stablecoins have overtaken bitcoin as the asset of choice amongcriminals using crypto, and as of 2024 accounted for approximately 63% of all illicit transactions(Chainalysis (2025); TRM Labs (2025)).1With growing interconnections between the crypto world and thetraditional financial system, strengthening the integrity of payment activity – by guarding against moneylaundering and other forms of illicit activity – has become more urgently necessary. Currently, rules to ensure anti-money laundering (AML) compliance rely on regulated financialintermediaries, especially the banking sector. In an intermediary-based monetary system, a payment isexecuted by debiting the sender’s account and crediting the receiver’s account. Customer checks can beconducted at the time of account updates, and the duty to perform them falls on the intermediary. Thisprinciple applies both domestically and to international payments through the correspondent bankingnetwork (CPMI (2016); BIS (2025)). Existinginternational standards for AML compliance for cryptoassets attempt to apply theintermediary-based principles for AML compliance to the crypto world.2However, there are clear limits tosuch an approach. Permissionless public blockchains rely on the operation of decentralised consensusmechanisms sustained by a dispersed set of self-interested “validators” who jointly maintain the recordsof transfers between addresses on the blockchain in a decentralised way. No individual intermediary maybe held accountable for the account update. While customer verification can be performed at points ofcontact with the conventional monetary system (eg by crypto exchanges) at the time of fund transfers into and out of the exchange, once claims move to unhosted wallets on the permissionless blockchain itself,the transactions are out of the reach of conventional forms of intervention.3While stablecoin issuers havefrozen balances at authorities’ request in high-profile cases of financial crime, such an approach isunrealistic to cover billions of day-to-day transactions. This Bulletin explores an alternative approach to AML compliance in permissionless blockchains whichutilises the very features that make them impervious to traditional approaches. As the full history oftransactions on the blockchain is publicly available, it could inform an assessment of how closely aparticular unit of a cryptoasset is associated with past or current illicit activity. A diagnostic “AMLcompliance score” could be referenced in any further interventions by authorities when cryptoassets(including stablecoins) are presented for conversion to fiat currency at the “off-ramps” – notably, at thepoint of contact with the banking system. The specific criteria for assessment could vary across jurisdictions. F