Virtual assets
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Advancing trust and standards between banks and virtual asset service providers – lessons from Wolfsberg Group events at the 9th Global Conference
By J. Edward Ned Conway, Executive Secretary, The Wolfsberg Group As virtual assets move into the mainstream of traditional finance, tricky questions arise. What does a reasonable, risk-based control framework look like for banks that provide services to virtual asset service providers VASPs ? And how can compliance teams strengthen private-to-private information sharing to better detect suspicious activity? These were some of the questions tackled by the Wolfsberg Group at the 9th Global Conference on Criminal Finances and Cryptoassets, organised by the Basel Institute on Governance, Europol and UNODC and held in Vienna on 28–29 October 2025. The Wolfsberg Group is an association of 12 global banks that develops frameworks and guidance for the management of financial crime risks. Housed at the Basel Institute on Governance, this long-standing initiative brings together senior financial crime compliance leaders through various working groups, including one dedicated to virtual assets. This flagship event provided a valuable platform for the Group to explain its Stablecoin Guidance, gauge interest in a specific Due Diligence Questionnaire focused on VASPs, and further advance efforts to break down silos in private-to-private information sharing. This blog summarises some of the key discussions – dialogues that are continuing in dedicated meetings and consultations of the Wolfsberg Group with members, regulators and institutional partners. Regulatory clarity as a catalyst for TradFi–VASP relationships? Day 1 of the conference saw Ned Conway, Executive Secretary of the Wolfsberg Group, moderate a high-level panel discussion featuring representatives from Circle, Bullish and Société Générale on the theme “Bridging the TradFi–DeFi Gap.” The panel discussed the barriers to relationship building between traditional finance TradFi institutions such as banks and VASPs such as cryptocurrency exchanges and stablecoin issuers. The speakers noted that a lack of trust and understanding persists, particularly around risks specific to virtual assets. That is one reason that TradFi is slow to onboard VASPs as clients and provide them with the banking services they need in order to operate. However, stablecoins are helping bridge this gap by bringing parts of the crypto universe under regulatory frameworks. TradFi institutions underlined that they would benefit from clearer scenarios from regulators on where collaboration and information sharing would be permissible between regulated entities and VASPs. Recent guidance issued by regulators on stablecoins and virtual assets in Asia, in particular, could help improve confidence both ways in the TradFi-VASP relationship. Aligning risk appetite, due diligence and monitoring for suspicious activity On Day 2, a dedicated Wolfsberg side event brought together VASPs, FinTech firms and traditional banks for in-depth discussions. Representatives from several Wolfsberg member banks – Deutsche Bank, Citi, UBS, Société Générale, and Bank of America – joined the sessions. The agenda focused on frameworks for information sharing, but the discussions touched upon a range of hot topics including: risk appetite and the risk-based approach; payment transparency i.e. the travel rule ; and approaches to monitoring for suspicious activity. During the discussions, participants highlighted that one of the main barriers to effective collaboration between traditional financial institutions and VASPs is a lack of mutual trust. Both sectors face difficulties in interacting with each other. The Wolfsberg Correspondent Banking Due Diligence Questionnaire CBDDQ is useful for setting standards, but onboarding challenges could be overcome by framing risk in common language. Many viewed the current onboarding approaches as fragmented, and expressed strong support for the Wolfsberg Group to develop standardised guidance and a due diligence questionnaire for VASPs. Questions remain about what is “reasonable” and “risk-based” for VASPs, especially for smaller institutions, and whether banks should monitor blockchain transactions themselves. VASPs need to be able to articulate their risk appetite, and how this changes as they continue to develop innovative products and services. VASP participants viewed the Wolfsberg Group’s Stablecoin Guidance as applicable beyond stablecoin issuers to the wider VASP ecosystem. This is particularly true for the tailored questions on the underlying control environment, and the linking of risk appetite directly to monitoring approaches. Improving private-private information sharing on suspicious activity Discussion on information sharing between TradFi and VASPs highlighted that this can rely heavily on personal relationships across entities, limiting scalability. VASPs showed concern around sharing wallet addresses under private-to-private information sharing frameworks, given geopolitical trends and concerns around the EU’s General Data Protection Regulation GDPR . However, consensus emerged that better data sharing both increases the quality of suspicious activity reports SARs and reduces SAR volumes. Particularly on this latter point, activities often thought to be suspicious in a silo are better understood when viewed from multiple perspectives, confirming the importance of information exchange. Continuing to build bridges as the financial system evolves Bridging the gap between TradFi and DeFi remains a central theme in the Wolfsberg Group’s strategy. The Vienna events offered a unique opportunity to engage key stakeholders across the sector and advance this important dialogue. The side event was opened by Elizabeth Andersen, Executive Director of the Basel Institute on Governance. The Wolfsberg Group extends its sincere thanks to the Basel Institute for the opportunity to co-host this side event and to participate in the 9th Global Conference on Criminal Finances and Cryptoassets. Learn more Learn more about the Wolfsberg Group and explores its guidance and resources on managing financial crime risk, including its Stablecoin Guidance. Learn more about the 9th Global Conference and see selected recordings. Find out about the 10th Global Conference on Criminal Finances and Cryptoassets on 15–16 September 2026 in Luxembourg.
Challenges in prosecuting crypto-related crimes – Q&A with Shenaz Muzaffer
Shenaz Muzaffer, General Counsel of the International Association of Prosecutors, spoke at the 8th Global Conference on Criminal Finances and Cryptocurrencies in a panel on “practical challenges in the investigation and prosecution of crypto-related financial crimes.” The two-day conference was co-organised by Europol and the Basel Institute on Governance and hosted by UNODC. This Q&A takes up the main points of her intervention on prosecuting crypto-related cases. Where do you see the main challenge for prosecutors in cases involving cryptocurrencies? Criminals are increasingly using crypto assets to facilitate the commission of their offences and to launder the proceeds of crime. Cryptocurrencies are being used to commit traditional crimes in new and innovative ways, as well as to commit new types of offences. To continue to be able to meet those challenges, we – as prosecutors – have to evolve and adapt too. But we face a number of challenges, relating to both the investigation and the prosecution of crypto-related financial crimes. The first challenge relates to the legislative framework in the jurisdictions in which we work. In many of our jurisdictions, if not in all, the relevant legislation was drafted prior to the invention of cryptocurrencies. We know that the first cryptocurrency was launched in 2009. But in the UK, for instance, the Fraud Act dates back to 2006, while the Proceeds of Crime Act is from 2002. This means that, because of the way the legislation is drafted, it can’t always be readily applied to the prosecution of crypto-related financial crimes. We need to ask, for example, whether the definition of “property” within existing legislation is broad enough to encompass crypto assets. It’s not only a challenge for the prosecution, but also for when we are looking to recover assets. We have to consider whether our legislative frameworks need to be revised or adapted to make sure that they are framed in a way which is broad and permissive enough so that we can capture these new types of offences and assets that we're dealing with. We must also ensure that we are cognisant of potential further changes that may arise in future and try, insofar as possible, to ensure that the legislation is sufficiently capable of encompassing them as well. Earlier this year, the UK introduced legislation that enables law enforcement to seize items such as memory sticks or written passwords, and also to transfer illegal crypto assets into a law enforcement wallet. Crypto-related crimes are often transnational in nature – how does this affect investigators and prosecutors? We all know that criminals don't respect jurisdictional boundaries and that crime is becoming increasingly international. So the second challenge from a prosecution point of view relates to jurisdictional issues. We also all know that coordination between law enforcement agencies and prosecutors can be slow and cumbersome, and that the formal process of seeking mutual legal assistance MLA comes with its own set of challenges. All these challenges reinforce the need for effective networks, both at a law enforcement and a prosecutorial level. It makes no sense for us to work in silos when we have to work across so many jurisdictions. That is why organisations such as the International Association of Prosecutors are absolutely critical. They enable prosecutors to build these necessary networks and facilitate formal and informal international cooperation. How can law enforcement officers and prosecutors keep up with this fast-evolving topic? Blockchain technology is inherently complex and new innovations such as non-fungible tokens NTFs are going to make things even more complex and complicated. The technical complexity of the subject matter is a very practical challenge. Consequently, it can be very challenging for prosecutors to properly understand the evidence that is presented to them by law enforcement. It's often even more difficult for those working within the courts, where judges and juries responsible for deciding on the facts of a case may never have come across crypto assets before. As a result, it can be incredibly hard for them to properly understand the relevance and the importance of evidence that's put before them. The solution, I would suggest, is twofold: For the prosecutors, there is an enhanced need for specialised training, so that we can properly understand the evidence we're presented with by investigators. For judges and juries, there’s a need to rely on experts that guide them through the process and help them understand the relevance of the evidence before them. Does digital evidence pose particular challenges? Yes, there are specific difficulties around the collection and preservation of the evidence. Digital evidence can be more easily altered. It can be encrypted. It can be deleted much more easily than other tangible forms of evidence. Establishing a chain of custody – a chronological documentation or paper trail that records when, how and by whom a piece of evidence was collected, analysed, controlled, transferred or disposed during an investigation – can be challenging itself, not to mention the added complexity caused by the sheer volume of the material that we have to deal with. Developing standard operating procedures or guidelines for the identification, collection and extraction of digital evidence, in my view, is absolutely vital. The same goes for using new technology to understand the evidence that is presented to us. Of course, artificial intelligence or AI plays an important role in this. The flipside is that we, as prosecutors, have to make sure that when we're using AI to interpret evidence, we are always cognisant of the need for transparency and accountability, and make sure that we are using AI responsibly. What challenges do crypto-related financial crimes pose for asset recovery? As practitioners we know that a case does not stop at the point of conviction. In fact, the investigation into the money side of things can often take longer than the investigation into the substantive crime itself. Crypto assets in particular can be moved very quickly at the touch of a button, which means that these assets can be very hard to trace and restrain. That also has a knock-on effect on public confidence because, if digital assets cannot be recovered and victims are not getting restitution, that impacts negatively on how they view the criminal justice system as a whole. One potential mitigation relates to the point I previously made about legislative frameworks –what they permit us to do and the need for revision. Let’s take another example from the new UK legislation I mentioned. This allows us to authorise the sale of crypto assets in the same way as more tangible forms of evidence. It also gives the police the power to destroy crypto assets, where returning them to circulation is not conducive to the public good. There’s no digital silver bullet, then? Unfortunately, there's no single solution that will address all the multiple challenges we’ve identified in both the investigation and prosecution of crypto-related financial crimes. Instead, we need a multi-pronged approach that includes enhanced training, the use of experts, expanded legislation, robust frameworks for evidence collection and, of course, more effective international cooperation.
Cryptocurrencies and financial crime: a strategic approach to ensure security
Investing in preventing and combating the misuse of the crypto ecosystem for financial crime is vital to safeguard both national and international security. This was a resounding message arising from the 8th Global Conference on Criminal Finances and Cryptocurrencies, which concluded on 12 September 2024 after two days of intense discussions and updates from leading voices in the field. The two-day hybrid conference attracted over 1,000 participants, including key stakeholders from the private sector, law enforcement, government bodies, intergovernmental organisations, academia and civil society. It was co-organised by Europol and the Basel Institute on Governance and hosted this year by the United Nations Office on Drugs and Crime UNODC at its headquarters in Vienna, Austria. New risks… The presentations and panels revealed emerging ways in which crypto assets and innovations are abused to facilitate organised crime. While cryptocurrencies pose no greater intrinsic risk than more traditional assets and value transfer systems, their unique features can be leveraged to facilitate ransomware attacks and other cybercrime, which can affect critical infrastructure and services. Speakers revealed cases of sophisticated misuse of crypto assets for money laundering, sanctions evasion, terrorist financing and nuclear proliferation, each carrying significant implications for both national and global security. …joint solutions The conference also showcased how law enforcement agencies are working collaboratively with crypto asset service providers, blockchain analysis firms and specialist asset recovery and management agencies to fight back. Emphasising the value of such events, Burkhard Mühl, Head of Europol's European Financial and Economic Crime Centre EFECC , commented: ”With events such as this Global Conference and the gathering and interaction of so many professionals and experts, we remain at the forefront of providing an appropriate response to the emerging financial crime risks and threats posed by the misuse of crypto assets. Europol will continue to support criminal investigations with all our capabilities and work with our partners to ensure that criminals are brought to justice.” These public-private collaborations have enabled officers to trace illicit crypto transactions across multiple blockchains before ultimately seizing the funds, de-anonymising the perpetrators and often being able to return significant quantities of crypto assets to victims. John Brandolino, UNODC Director, Division of Treaty Affairs, emphasised that: “Multilateral collaboration is essential to dismantling the finances of criminal organisations and terrorists. UNODC fully supports and promotes efforts to collectively strengthen our ability to prevent and counter the criminal misuse of crypto assets, which in turn contributes to overall global security”. Meanwhile, more stringent regulations in the European Union and other jurisdictions are starting to bring the crypto ecosystem firmly into the regulated sphere. If implemented effectively, they will provide a robust framework for law enforcement and asset recovery while also setting clear guidelines for private-sector entities and supervisors. A strategic priority Investing in capabilities and effective measures to prevent and combat the misuse of the crypto ecosystem for financial crime should be a strategic priority across all sectors. Iker Lekuona, Director of the Basel Institute’s International Centre for Asset Recovery ICAR , said: In our work assisting with major transnational corruption and asset recovery cases, we see how money launderers and other criminals systematically target weak links in the chain. All institutions involved in detecting and investigating financial crimes and in recovering assets need to build their capacity to work on crypto-related cases. Mr. Brandolino added: “Tackling illicit profits has consistently proven to be one of the most effective strategies for disrupting criminal organisations and preventing the misuse of cryptocurrencies for illegal purposes”. As emphasised in the joint Europol–Basel Institute recommendations published earlier in 2024, this includes investing in research and innovation, capacity building and cross-border, multi-stakeholder collaborations. Joint learning and collaborations Peer learning opportunities like this Global Conference series are vital to advancing all of these areas. They are a key element of the strategic approaches of all three partner organisations for this conference, including Europol’s 2023 Delivering Security in Partnership strategy and the Basel Institute’s strategic pillars of building coalitions and catalysing joint learning. Learn more View a selection of presentations on YouTube. See 2024 joint recommendations: A race against time: Europol – Basel Institute on Governance recommendations on preventing and combating the criminal use of cryptocurrencies
Registration open: 8th Global Conference on Criminal Finances and Cryptocurrencies
Registration is now open for the 8th Global Conference on Criminal Finances and Cryptocurrencies 8CrC . This year's conference is co-organised by Europol and the Basel Institute on Governance and will be hosted by UNODC at its headquarters in Vienna, Austria. You can register here. The hybrid conference explores trends, strategies and tactics in tackling crimes involving virtual assets. A joint initiative of the Basel Institute on Governance and Europol, the annual event now draws hundreds of experts and interested parties from around the world. Multi-stakeholder discussions Through short presentations, panel discussions and case studies, the conference participants seek to illuminate how criminals can abuse the virtual asset ecosystem and develop recommendations on what law enforcement, regulators and the private sector can do about it. Confirmed speakers on day 1 span the private sector including major virtual asset service providers and blockchain analytics firms , law enforcement and relevant regulatory or supervisory authorities. View draft agenda for day 1. Day 2 features international cryptocurrency investigators sharing case studies and typologies. Attendance on day 2 is strictly limited to law enforcement agencies and related public authorities such as financial intelligence units and supervisory authorities. Hybrid conference The conference will be held in a hybrid format, with 200 spaces available for in-person attendance on each day. Attendance is free but pre-registration is required. Update 21 July: In-person registration is now closed as we are at full capacity; you may register virtually and/or request to be placed on the waiting list. Learn more and register Register here View draft agenda for day 1 View the 2023 conference joint press release by Europol and the Basel Institute on Governance View the post-conference recommendations: A race against time: Europol – Basel Institute on Governance recommendations on preventing and combating the criminal use of cryptocurrencies
Shaping an international response against the criminal misuse of cryptocurrencies
A hybrid international conference attended by 1,300 participants has concluded that tackling the criminal use of cryptocurrencies is a race against time. Law enforcement agencies that collaborate in joint task teams and proactively collaborate with the private sector are getting ahead of the criminals. In contrast, countries that do not take the risks seriously are in danger of becoming a haven for crypto-enabled scams, money laundering and terrorist financing. Co-organised by Europol and the Basel Institute on Governance, the 7th Global Conference on Criminal Finances and Cryptocurrencies was hosted at Europol’s headquarters. The two-day event 26-27 October , organised in a hybrid format, was attended by representatives from law enforcement, the public and private sectors, policy institutions and academia from more than 100 countries. The aim was to explore trends and strategies to tackle crimes involving cryptocurrencies. The discussions focused on the key issues associated to combating the criminal misuse of these virtual assets, including: Trends and threats in relation to the criminal use of cryptocurrencies, including evolving scam typologies. Growing adoption of cryptocurrencies by criminals, particularly in underground banking. Evolving legal frameworks around virtual assets in the European Union. Current institutional capacity to tackle money laundering, terrorist financing and other crimes involving cryptocurrencies. Public-private cooperation in cryptocurrency investigations and confiscation proceedings. Best practices in investigative and regulatory responses. On the second day of the conference – which was restricted to law enforcement only – national investigators and Europol shared their experiences in cryptocurrency investigations. Among the topics of discussion were methodologies for exploring criminal operations in dark markets and scams involving cryptocurrencies. The conference participants converged around a set of recommendations to strengthen skillsets, improve knowledge, boost expertise and encourage best practices for crypto assets investigations and recovery. Peer learning forums such as this conference are key to achieving all of these challenges. Jean-Philippe Lecouffe, Europol’s Deputy Executive Director Operations, said: Criminals aren't giving up on misusing cryptocurrencies anytime soon. Europol's Strategy 'Delivering Security in Partnership', adopted earlier this year, highlights the pivotal role that cryptocurrencies play in the financial schemes of criminals. Europol is convinced of the value of partnering with the Basel Institute on Governance to bring together representatives from law enforcement and the private sector from across the world to share their insights and to collaborate on how we respond to emerging technologies. Gretta Fenner, Managing Director of the Basel Institute on Governance, said: Our Basel AML Index shows that countries struggle to address money laundering and terrorist financing risks related to virtual assets. Events like this are crucial to build capacity in law enforcement and maximise the opportunities of public-private and cross-border collaboration. We are proud to partner with Europol to organise the conference for the seventh year. The annual conference is organised by the Working Group on Criminal Finances and Cryptocurrencies, established in 2016 and led by the Basel Institute on Governance and Europol. This is a joint press release also published on the Europol press centre.
Publications
A race against time: Europol – Basel Institute on Governance recommendations on preventing and combating the criminal use of cryptocurrencies
These recommendations follow the 7th Global Conference on Criminal Finances and Cryptocurrencies on 26–27 October 2023. The conference was co-organised by Europol and the Basel Institute on Governance and took place in hybrid format at Europol’s headquarters in The Hague, Netherlands.
The five recommendations highlight the need for accelerated action in order to combat the use of crypto assets, as well the allocation of more resources, better training and better collaboration.
They are to:
- Accelerate innovation for investigative and monitoring tools
- Boost enforcement capacity and training
- Reorganise to foster collaboration and prioritisation
- Engage proactively in multi-sector collaborations
- Consider the whole chain, from prevention to facilitators
Seizing the opportunity: 5 recommendations for crypto assets-related crime and money laundering
These recommendations follow the 6th Global Conference on Criminal Finances and Cryptocurrencies on 1–2 September 2022. The conference was hosted by Europol at its headquarters in The Hague, the Netherlands, together with the Basel Institute on Governance through the Joint Working Group on Criminal Finances and Cryptocurrencies.
The Recommendations are intended to highlight broad approaches and best practices. They are designed to help public and private actors stay one step ahead of those seeking to abuse crypto assets (also known as virtual assets) and services to make, hide and launder illicit money.
The main message is that as the use of crypto assets expands into practically every country and sector, so does its abuse to commit new forms of crime and launder criminal proceeds. Yet with the right tools, capacity and cooperation, the unique characteristics of blockchain-based technologies offer an unprecedented opportunity to investigate organised crime and money laundering networks and to recover stolen funds.
The five recommendation cover:
- Break down silos between “traditional” and “crypto”
- Regulate broadly and make full use of existing laws
- Take advantage of the blockchain to disrupt organised crime
- Raise crypto literacy through capacity building and clear communication
- Increase public-private cooperation
Working Paper 38: Cryptocurrencies in Asia and beyond: law, regulation and enforcement
The crypto industry has exploded in recent years, and authorities in different countries have been reacting in very different ways. Some have banned cryptocurrencies, while others are embracing them to varying degrees. Some are working hard to align their anti-money laundering regulations with FATF standards, while others are turning a blind eye. A few countries have confiscated huge quantities of crypto assets linked to crime and money laundering. Others are at square one in terms of enforcement, risking becoming a hub for crypto crime and money laundering and posing a serious vulnerability in the world’s financial system.
This Working Paper draws on a detailed analysis of how selected countries are addressing legal, regulatory and enforcement issues around cryptocurrencies and other virtual assets. The analysis is focused on Asia, but set in the context of global trends in crypto law, regulation and enforcement. It explores critical questions that will shape policies around virtual assets at the corporate, national and international levels:
- What is working in terms of crypto regulation and enforcement?
- What are the implications of different policy choices on crypto assets – for the industry, for the countries themselves and for global financial integrity as a whole?
- What would the crypto wave possibly bring next?
The Paper also highlights broader developments needed to bring light and clarity to laws, policies and practices around the crypto industry, such as collaboration between both market players and governments.
Jurisdictions touched upon in this Working Paper alphabetically include Bhutan, Central African Republic, El Salvador, Hong Kong SAR, India, Indonesia, Japan, Kazakhstan, Malaysia, Myanmar, Russia, Singapore, South Korea, the Philippines, the People’s Republic of China, Thailand, Ukraine and Vietnam.
A list of key terms and abbreviations have been prepared in the Annex to this Working Paper for the readers’ easy reference.
About this Working Paper
This Working Paper is a collaboration between Dorothy Siron, Co-Managing Partner, Zhong Lun Law Firm LLP and Federico Paesano, Senior Financial Investigation Specialist, Basel Institute on Governance.
Dorothy Siron provided the bulk of the analysis and discussion, while Federico Paesano provided a selection of case studies and was co-author of the seven recommendations contained in section 4. The collaboration was facilitated by the International Academy of Financial Crime Litigators, an independent, non-partisan global centre that shapes and advances financial crime litigation practices for the future.
The publication is part of the Basel Institute on Governance Working Paper Series, ISSN: 2624-9650. It is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License (CC BY-NC-ND 4.0).
Suggested citation: Siron, Dorothy, and Federico Paesano. 2022. “Cryptocurrencies in Asia and beyond: law, regulation and enforcement.” Working Paper 38, Basel Institute on Governance. Available at: https://baselgovernance.org/publications/wp-38
Disclaimer: This Working Paper does not, and is not intended to, constitute and/or substitute legal or other professional advice. The content of this Working Paper is updated as of 4 May 2022 and is intended for general informational purposes only. No representations have been made as to its accuracy and completeness. You should seek independent legal or other professional advice before acting or relying on any of the information contained herein.
Combating virtual assets-based money laundering and crypto-enabled crime: Recommendations of the Tripartite Working Group on Criminal Finances and Cryptocurrencies
These seven Recommendations emerge from the 5th Global Conference on Criminal Finances and Cryptocurrencies, held virtually on 7-8 December 2021.
The annual conference is organised by the Working Group on Criminal Finances and Cryptocurrencies, a tripartite initiative of the Basel Institute on Governance, INTERPOL and Europol that dates back to 2014 and was formally established in 2016.
The Recommendations are intended to guide law enforcement, judicial authorities, regulators and the private sector in broad approaches that are necessary to protect citizens and the global economy from the risks of abuse of cryptocurrencies and other virtual assets.
They cover:
- International cooperation
- Virtual asset recovery
- Public-private cooperation
- Harmonised regulation and its effective implementation
- Investigative techniques and technologies
- Capacity building
- Multidisciplinary approach, including through specialised law enforcement units
Cryptolaundering: anti-money laundering regulation of virtual currency exchanges
This paper discusses anti- money laundering regulation for virtual currency intermediaries, by showcasing and comparing regulatory models at the national and international levels.
It is found that anti-money laundering regulation for virtual currencies — more than being merely “nice to have” — contains considerable potential in the fight against economic crime. Where financial intermediaries engaged in virtual currencies are required to gather the full spectrum of information needed to identify their customers and the source of funds, virtual currencies become much less attractive to money launderers than traditional fiat money systems. Furthermore, anti-money laundering regulation means that supervisory and investigatory authorities can identify and act against money launderers and other delinquents.
The author presented this paper at a conference at the University of the Western Cape, South Africa, in October 2018. It was published in the Journal of Anti-Corruption Law (Volume 3, Number 2: 2019, pp1-15).
The author would like to emphasise that the world of cryptocurrencies and money laundering regulation moves fast and many things may have changed since the paper was written.