This paper discusses anti- money laundering regulation for virtual currency intermediaries, by showcasing and comparing regulatory models at the national and international levels. 

The Panama Papers provided proof to the world of something that had long been suspected: the secrecy havens – jurisdictions in which global financial flows were hidden in ways that not even those entrusted with enforcing the laws and regulations of countries around the world could detect – were being used by those engaged in a host of nefarious activities, from tax evasion to corruption and even to child pornography.

These Principles draw on the Basel Art Trade Guidelines originally issued in draft in 2012 and reissued in 2018 without any material changes. This paper seeks to complement and set out in more detail the anti-money laundering aspects of the 2012/2018 Guidelines.

Anti-money laundering systems have the potential to curb the use of proceeds of corruption and other crimes by the perpetrators. An effectively implemented anti-money laundering framework limits the channels through which illicit funds can be laundered, making crime riskier and reducing the incentives for corrupt activities.

Switzerland is frequently accused of being reluctant to take thorough measures to fight money laundering. Both the Swiss authorities and the banks in Switzerland strongly reject such accusations. We are convinced that our anti-money laundering measures are best market practice.