2021 was a precedent-setting year for anti-money laundering (“AML”) enforcement and legislation. The digital assets industry continued to grow exponentially, driving the associated AML risks to the forefront of regulatory concerns. In the United States, the new administration established corruption, including money laundering, as a core national security interest. Legislators and regulators alike called for a “whole of government” approach to combatting illicit activity associated with cryptocurrencies, and federal agencies—from OFAC to the FDIC—issued long-awaited guidance for the virtual asset industry.
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