国际清算银行-加密资产反洗钱合规方法（英）

BIS Bulletin No 111 Iñaki Aldasoro, Jon Frost, Sang Hyuk Lim, Fernando Perez-Cruz and Hyun Song Shin 13 August 2025 An approach to anti-money laundering compliance for cryptoassets BIS Bulletins are written by staff members of the Bank for International Settlements, and from time to time by other economists, and are published by the Bank. The papers are on subjects of topical interest and are technical in character. The views expressed in them are those of their authors and not necessarily the views of 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 Wooldridge for helpful comments and suggestions, Giulio Cornelli for excellent research assistance, Emma Claggett for 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 or translated provided the source is stated. ISSN: 2708-0420 (online) ISBN: 978-92-9259-881-5 (online) BIS Bulletin: An approach to anti-money laundering compliance for cryptoassets 1 Iñaki Aldasoro Inaki.Aldasoro@bis.org Jon Frost Jon.Frost@bis.org Sang Hyuk Lim Sanghyuk.Lim@bis.org Fernando Perez-Cruz Fernando.Perezcruz@bis.org Hyun Song Shin Hyunsong.Shin@bis.org An approach to anti-money laundering compliance for cryptoassets Key takeaways • Existing anti-money laundering (AML) approaches relying on trusted intermediaries have limited effectiveness with decentralised record-keeping in permissionless public blockchains. • The public transaction history on blockchains can enable AML and other compliance efforts, such as FX regulations, by leveraging the provenance and history of any particular unit or balance of a cryptoasset, including stablecoins. • An AML compliance score based on the likelihood that a particular cryptoasset unit or balance is linked 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” among crypto market participants. Cryptoassets circulating on permissionless public blockchains have grown in heft rapidly and are becoming increasingly integrated with the mainstream financial system. As their usage expands, concerns about illicit activity have also grown. Since 2022, stablecoins have overtaken bitcoin as the asset of choice among criminals using crypto, and as of 2024 accounted for approximately 63% of all illicit transactions (Chainalysis (2025); TRM Labs (2025)).1 With growing interconnections between the crypto world and the traditional financial system, strengthening the integrity of payment activity – by guarding against money laundering and