Cryptocurrency has quickly evolved from an instrument of the black market to an industry all its own. Cryptocurrency market participants still include bad actors, but now also include established financial institutions and startup organizations seeking to disrupt the financial services sector. While financial institutions often maintain robust Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Asset Control (OFAC) Compliance Programs, startup organizations frequently lack the expertise and funding to do the same. Across both entity types, exposure to cryptocurrencies presents unique money laundering, sanctions, and regulatory risks that must be considered as the organization modifies or builds an effective BSA/AML and OFAC Compliance Program.
In an article for Corporate LiveWire's Fraud & White Collar Crime 2019 Expert Guide, Alma Angotti, Elizabeth Sisul, and Brandy Schindler discuss key risk considerations for organizations that have exposure to the cryptocurrency industry. In addition, they present risk management best practices for organizations that are amending or building a BSA/AML and OFAC Compliance Program that effectively addresses those risks.