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The supervision of crypto asset service providers (CSPs) remains nascent globally.
As jurisdictions finalize regulation, the key question remains as to who and which activities fall within the regulatory perimeter
The question in turn depends on the authorities’ assessment of which risks posed by crypto assets and related activities should be captured by regulation and, in such case, whether those risks are captured by existing regulation or whether there is a gap that needs to be addressed.
Overall, most supervisors have an open dialogue with the private sector and provide an “on-ramp” period for service providers.
While much work remains on implementation, most jurisdictions have performed or are in the process of performing an AML/CFT national risk assessment.
Enforcement actions remain limited in number and have been undertaken by very few jurisdictions, leaving room for improvement.
The travel rule is a binding FATF obligation, but most jurisdictions have not effectively implemented it.
P2P transactions pose challenges, but views differ as to their magnitude.
There is an opportunity to adopt new approaches that take advantage of the inherently data-rich nature of the crypto asset sector.
International cooperation to oversee this sector effectively is key.
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