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The convergence of Financial Technology (fintech) and Anti-Money Laundering (AML) practices has become a critical focal point in the global fight against financial crimes. As fintech continually transforms traditional financial services, its groundbreaking innovations bring forth both prospects and complexities in upholding stringent AML compliance standards.

In this landscape, the definition and classification of Virtual Assets (VAs) play a pivotal role. These digital representations of value, excluding fiat currencies and securities, encompass various forms like cryptocurrencies, payment tokens, and convertible virtual currencies. Meanwhile, Non-Fungible Tokens (NFTs) or crypto-collectibles, unique digital assets primarily used as collectibles, pose distinct challenges in classification due to their evolving functions and practical applications.

The classification of entities engaging in Virtual Asset Service Provider (VASP) activities, encompassing exchanges, transfers, safekeeping, and financial services related to virtual asset offerings, falls under the purview of multiple regulatory bodies within the UAE. These agencies, including the UAE Securities and Commodities Authority (SCA), the Virtual Asset Regulatory Authority (VARA), and others, meticulously supervise and regulate VASPs to ensure compliance with AML/CFT frameworks.

As defined in the AML-CFT Decision, as amended, a virtual asset service provider is any person— whether an individual or a company—that conducts any of the following five activities (“VASP activities” or “covered VASP activities”) as a business on behalf of other individuals or companies. Note that the descriptions and examples of the five covered VASP activities presented below are provided for illustrative purposes only and are not intended to be comprehensive.

  1. Exchange between virtual assets and fiat currencies
  2. Exchange between one or more forms of virtual assets
  3. Transfer of virtual assets
  4. Safekeeping or administration of virtual assets or instruments enabling control of virtual assets
  5. Participation in and provision of financial services related to an issuer’s offer or sale of a virtual asset

Multiple regulatory and supervisory agencies comprise the UAE’s AML/CFT framework for virtual asset service providers (“VASPs”), including: the UAE Securities and Commodities Authority (“SCA”), which serves as the licensing and primary regulatory authority for VASPs at the Federal level and for the UAE’s Commercial Free Zones (“CFZs”); the Virtual Asset Regulatory Authority (“VARA”), which serves as the regulator of VASPs in the Emirate of Dubai; the Financial Services Regulatory Authority (“FSRA”), which regulates VASPs in the Abu Dhabi Global Market (“ADGM”); the Dubai Financial Services Authority (“DFSA”) which regulates VASPs in the Dubai International Financial Centre (“DIFC”) and the CBUAE, which supervises LFIs and RHPs, including in their capacity as financial service providers to VASPs and to non-VASP customers that may engage in virtual asset (“VA”) transactions. Additional detail on the UAE legal and regulatory framework for VASPs, including references to specific guidance issued by the aforementioned authorities. Prior to and during engagements with VASPs, LFIs and RHPs should consider the relevant jurisdiction and/or asset specific regulations mandated by the aforementioned supervisory agencies.



Fintech companies have disrupted the financial industry, offering innovative solutions such as mobile payments, peer-to-peer lending, blockchain-based transactions, and automated financial advisory services. These technologies have transformed the way people transact, invest, and manage their finances. However, this rapid evolution has also introduced complexities in ensuring compliance with AML regulations.


In the UAE, the legal and regulatory framework mandates reporting of suspicious transactions by VASPs to the UAE Financial Intelligence Unit (FIU). Additionally, licenses or registrations from competent supervisory authorities are prerequisites for individuals or entities engaging in VASP activities. Regulators like the SCA, CBUAE, and VARA define and regulate specific VASP activities and provide guidance to ensure adherence to AML/CFT laws.


The SCA regulates platforms that enable the trading of virtual assets, authorized persons that carry out virtual asset custody services, and virtual asset intermediaries. The SCA defines virtual assets as digital representation of value that can be digitally traded or transferred and can be used for investment purposes and does not include digital representations of fiat currency, securities, or other money. A virtual asset, so defined, is neither issued nor guaranteed by any sovereign state or jurisdiction and fulfils the above functions only by agreement within the community of users of the virtual asset. A full description of regulated activities in relation to virtual assets and virtual asset service providers is provided in Cabinet Resolution No. (111) of 2022 on the Regulation of Virtual Asset Service Providers.


The CBUAE licenses Payment Token Service Providers pursuant to the Central Bank’s Retail Payment Services and Card Schemes Regulation.14 Under this regulation, Payment Tokens are defined as a type of Crypto-Asset that is backed by one or more Fiat Currency, can be digitally traded, and functions as a medium of exchange and/or a unit of account and/or a store of value, but does not have legal tender status in any jurisdiction. A Payment Token is neither issued nor guaranteed by any jurisdiction and fulfils the above functions only by agreement within the community of users of the Payment Token. Payment Token Service Providers, in turn, are defined as persons engaged in Payment Token issuing, Payment Token buying, Payment Token selling, facilitating the exchange of Payment Tokens, enabling payments to Merchants and/or enabling peer-to-peer payments, and Custodian Services related to Payment Tokens. 

Additionally, under the Stored Values Facilities (“SVF”) Regulation of 2020 (Circular No. 6/2020), the CBUAE licenses and supervises providers of SVFs, defined as facilities (other than cash) used by a customer to store money or “Money’s Worth” and transfer such money or “Money’s Worth” as a means of payment. Under the SVF Regulation, “Money’s Worth” includes “other forms of monetary consideration or assets such as values, reward points, Crypto-Assets, or Virtual Assets.” To the extent that providers of SVFs engage in the VA exchange or transfer activities or other VASP activities, as described in section 1.5 above—including by facilitating companies accepting VA as payment—they fall under the definition of a VASP and must be licensed to operate as such by UAE authorities.


Under Law No. 4 of 2022 on the Regulation of Virtual Assets in the Emirate of Dubai, a virtual asset is defined as a digital representation of value that can be digitally traded, transferred, or used as an exchange or payment tool or for investment purposes, and any digital representation of any other value as determined by VARA. Virtual assets, so defined, include “virtual tokens,” defined as digital representations of a set of rights that can be digitally issued and traded through a virtual asset platform. VARA, within the scope of the above-mentioned law and Cabinet Decision No. (112) of 2022, and without prejudice to the regulatory powers of the CBUAE and SCA, serves as the regulatory authority for VAs in the Emirate of Dubai responsible for authorizing any entity to undertake VA-related activities, including specifically licensing VASPs to carry out activities related to VAs.

VASPs are defined by this Law as any person authorized by VARA to conduct any activities that require a license from VARA and are subject to VARA oversight, per Article 16 of Law No. 4 of 2022.


Fintech innovations offer several avenues for enhancing AML efforts:

1. Onboarding and Identity Verification: 

Like other regulated entities in the financial space, crypto firms must perform identity verification checks and KYC measures to establish and verify the identity of their customers. Given that once initiated, crypto transactions can take mere seconds to complete, there is increased pressure to get the on-boarding piece right. To mitigate risks, crypto firms would do well to consider using a layered approach to identity verification. For example, firms may choose to conduct an examination of identity documents in addition to a video or photo KYC check as a matter of course. It may also be worth considering slowing down the onboarding process by instituting a mandatory 24-hour wait between onboarding and completing transactions. High-risk customers may prompt the firm to undertake other, more evolved due diligence measures.

2. Screening and monitoring: 

Even after onboarding a customer, crypto firms must be able to accurately and efficiently monitor their customers for changes. If they have been added to sanctions or watch lists, if there are changes in their politically exposed person (PEP) status, or if the status of any relatives and close associates (RCAs) notably changes, this may necessitate swift action. Additionally, crypto firms would do well to ensure they have the tools needed to detect whether their customers have been involved in adverse media stories, as that might trigger a higher level of scrutiny and monitoring.

3. Transaction Monitoring: 

This area of compliance is arguably where crypto firms and traditional banking diverge the most. Brandi Reynolds, Managing Director at Bates Group, a consultancy, and outsourced CCO for eToro USA and Voyager Digital NY, says: “Firms often do not recognize the importance of transaction monitoring, often over relying on KYC at the expense of other controls.”

Like banks, crypto firms are expected to monitor and understand the transactional behavior of their customers and scan for suspicious activity. However, the speed with which transactions occur and the variety and volume of data transmitted with each transaction, especially when one cryptocurrency is converted into another, can make it challenging to keep pace. In addition, firms must ensure their transaction monitoring tools are tailored and calibrated to ensure proper scrutiny of transactions where cryptocurrencies are cashed out and converted to fiat currency — something traditional banks don’t typically need to prioritize.

It is here where proper segmentation of customers is crucial. Crypto firms should thoroughly examine any personally identifiable information (PII) and leverage behavioral analytics to help profile customers and set rules according to expected behaviors. The more comprehensive a firm’s segmentation, the better able that firm will be to assess the level of risk a transaction poses, whether that risk is due to the customer, the counterparty or the jurisdictions involved.


1. Ransomware

Digital adoption has increased cybercrime risks, particularly ransomware attacks. These attacks block access to critical data until victims pay a ransom, often in cryptocurrency. Ransomware attacks increased by 105% globally in 2021 compared to 2020. Regulators are exploring tightening controls to address this threat. High-profile targets include the San Francisco 49ers and Nvidia Corporation. Payments due to ransomware attacks may involve multiple wallet addresses and layering strategies.

2. Sanctions Evasion 

Russia’s war in Ukraine and Western sanctions have sparked discussions about crypto evasion. While no evidence exists of Russian individuals using crypto to avoid sanctions, regulators are taking this issue seriously. Crypto firms must screen new customers against sanctions lists, calibrate transaction monitoring protocols, and monitor IP addresses for high-risk transactions. Red flags include rapid transactions involving multiple wallets and anonymity-enhanced cryptocurrencies.

3. Darknet Markets

Online marketplaces for illicit goods and services pose a threat to crypto firms, as participants often use virtual currencies as payment. Bitcoin is currently the most preferred cryptocurrency, but monero may overtake it in the future. Governments and law enforcement have intensified efforts to disrupt and take down these darknet markets.

4. Fraud

Cryptocurrency fraud is expected to rise as cryptocurrencies become more widely used. A Chainalysis report found that $14 billion was directed to criminal addresses in 2021, nearly double the amount in 2020. Scams and stolen funds were the most common crimes. An emerging scam called rug pull occurs when developers sell tokens to raise capital, leaving investors with losses. Stolen funds accounted for $3.2 billion in 2021, primarily from DeFi protocols. 

5. Terrorist Financing 

Cryptocurrency assets and DeFi are used in terrorist financing due to their anonymity and ease of cross-border transactions. The fragmented regulatory landscape increases the likelihood of suspicious transactions going undetected. Bitcoin is often used by terrorists, but privacy-enhanced coins like monero are increasingly seen as more desirable alternatives. Crypto firms should scrutinize transactions involving anonymity-enhanced cryptocurrencies, especially if the portfolio consists of these cryptocurrencies.

6. Geopolitical Unrest

Cryptocurrency mining operations have been disrupted by geopolitical tensions and domestic unrest, particularly in countries like Kazakhstan. High fuel prices and power shortages have led to domestic unrest, prompting Kazakhstan’s government to suspend operations. Crypto firms must be prepared to react to untenable situations and mitigate potential threats, whether directly or indirectly through partner companies or regulatory consequences.


Fintech Companies must ensure that their technology governance and risk assessment framework complies with, to the extent applicable, cybersecurity laws, regulatory requirements and guidelines, including but not limited to – 


While fintech innovations offer promising avenues, they also present unique compliance challenges:

1. Regulatory Complexity

Fintech companies operate in a rapidly evolving regulatory landscape. Complying with diverse AML regulations across different jurisdictions poses a significant challenge, requiring continuous adaptation to stay compliant.

2. Data Privacy and Security

The collection and utilization of extensive customer data by fintech firms raise concerns about data privacy and security. Balancing the need for data access to enhance AML measures while safeguarding customer information is critical.

3. Dynamic Nature of Financial Crimes

Criminals constantly adapt their tactics to exploit vulnerabilities in fintech platforms. Staying ahead of sophisticated money laundering techniques requires continuous innovation and proactive measures.


To navigate these challenges, fintech companies must prioritize a holistic approach that integrates innovation with compliance:

1. Collaborative Efforts

Collaboration among fintech firms, regulatory bodies, and traditional financial institutions is essential. Sharing best practices and insights can foster a more comprehensive approach to combat financial crimes.

2. Invest in Robust AML Technology

Continued investment in cutting-edge AML technology, including AI-powered analytics and blockchain solutions, is crucial. This helps in creating more robust defense mechanisms against evolving money laundering tactics.

3. Emphasize Education and Training

Educating employees and stakeholders about AML regulations and emerging risks is fundamental. Training programs ensure a better understanding of compliance requirements and foster a culture of compliance within fintech organizations.

Empowering Fintech & Crypto Compliance: LFL International Group’s Innovative Solutions

LFL International Group stands at the forefront of assisting fintech and crypto companies in navigating the intricate landscape of compliance, particularly concerning Anti-Money Laundering (AML) practices. With the convergence of fintech innovations and stringent AML standards, LFL International Group offers comprehensive solutions tailored to meet the evolving regulatory requirements. Through collaborative efforts, LFL facilitates a deep understanding of the dynamic nature of financial crimes and the diverse AML regulations across jurisdictions. Leveraging cutting-edge AML technology, including AI-powered analytics and blockchain solutions, LFL empowers clients to establish robust defense mechanisms against evolving money laundering tactics. Moreover, emphasis on education and training ensures that stakeholders and employees are equipped with the necessary knowledge to adhere to compliance protocols effectively. By prioritizing a holistic approach that integrates innovation with compliance, LFL International Group ensures that crypto firms not only navigate regulatory complexities but also foster trust, enhance productivity, and pave the way for sustained success in the fintech ecosystem.


Compliance professionals will most likely look back on 2022 as a defining year for crypto. If current trends continue, it is set to mark the point at which adoption of cryptocurrencies and regulatory reforms collide, leading to a sector that is more regulated, and increasingly mainstream. Regulatory arbitrage will, however, remain one of the biggest challenges crypto firms must grapple with. 

Staying ahead of the regulatory curve, alongside smart investments in AML technologies and a diverse compliance staff, will set crypto firms up for success. Not only will they have better relationships with regulators and policymakers, but productivity will increase, and customers will trust the products and services they offer more.

To strike a balance between innovation and compliance, collaborative efforts among fintech firms, regulatory bodies, and traditional financial institutions are indispensable. Continued investment in cutting-edge AML technology, coupled with comprehensive education and training programs, forms the cornerstone of a holistic approach to combat financial crimes.

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