As part of its mission to facilitate the adoption and use of distributed ledger technologies (DLT) in financial markets, the CMTA has published an updated version of its Anti-Money Laundering (AML) standards for the treatment of digital assets by issuers and financial intermediaries.

First published in 2018, the standards aim to clarify for both issuers of digital assets and financial intermediaries how to comply with the Swiss regulations against money laundering and the financing of terrorism.

In this 2024 version, the AML Standards have been updated to reflect the latest developments, particularly around the travel rule. The AML Standards are now split into two documents, providing respectively Standards for Issuers and Standards for Financial Intermediaries.

The goal of the standards is to provide a framework that facilitates the use of DLT and the opportunities this brings to financing businesses, while preventing issuers of digital assets from being recipients of illicit funds. The standards represent a consensus among significant actors in the financial sector as to how applicable rules and regulations can be complied with, and more generally, provide an expression of good practice for the treatment of digital assets. The standards have no statutory or regulatory status and are not compulsory, but rather provide an example risk-based approach and practical toolkit on which issuers and financial intermediaries may base their own AML/CFT procedures.

Significant points of the updated standards include:

Digital Assets - AML Standards for Financial Intermediaries:

• Distinction between business relationships with investors in digital assets, merchants, and VASPs.
• Recommendations on how to, among other points:

1. - Know Your VASP;
2. - Conduct blockchain forensic analysis for public wallet addresses;
3. - Ask for proof of wallet ownership; and
4. - Comply with the travel rule

• The appendix contains examples of due diligence questionnaires for issuers, investors in digital assets and merchants, as well as an example of high risk criteria for digital asset transactions.

Digital Assets - AML Standards for Issuers:

• Recommendations on how to, among other points:

1. - Check for licensing requirements;
2. - Identify the contributor and establish the beneficial owner;
3. - Identify multiple participations from the same contributor through controls;
4. - Conduct blockchain forensic analysis for public wallet addresses;
5. - Ask for proof of wallet ownership; and
6. - Apply additional requirements for Tier 3 contributor level.

We appreciate the public's feedback on these standards and look forward to receiving any comments to info@cmta.ch.

• Go to CMTA's Digital Assets - AML Standards