"Allowing VASPs to support privacy tokens under current, tested AML regulations strikes the appropriate policy balance between preventing money laundering and allowing beneficial, privacy-preserving technology to develop."
"Not only do privacy coins provide public benefits that substantially outweigh their risks, existing AML regulations properly and sufficiently cover those risks, providing a proven framework for combatting money laundering and related crimes."
"Businesses rely on and expect financial privacy. Without maintaining confidentiality, commercial transactions would be visible for competitors and nefarious actors to analyze, predict, front-run, and exploit."
"...privacy coins have enabled users to transact in a low-cost, decentralized manner, while maintaining the added benefit of financial privacy that was only previously available through financial intermediaries and institutions in the traditional financial system."
"Privacy coins essentially combine the benefits that the traditional financial system and initial cryptocurrencies like Bitcoin offered."
"... [the NYDFS] similarly does not require the use of on-chain surveillance tools. When these on-chain surveillance tools are not available, regulated companies can still meet their compliance obligations through other robust means of off-chain information sharing."
"Even in the case of privacy coins, VASPs should and will remain the primary subject of AML and CFT regulations, just as they do in traditional financial transactions."
"privacy coins and other cryptocurrencies arguably pose a lower risk, in [the "ease of crossing borders" factor], than cash, card, or paper payment instruments, which can cross borders with no transfer record at all (i.e., not even a publicly broadcast blockchain transaction)."
"If anything, privacy coins pose lower inherent AML risk than other cryptocurrencies when considering evidence of illicit use in practice."
"privacy coins do not pose an inherent AML risk that is uniquely or unmanageably high, since that risk does not appear materially greater than other high-risk traditional products that VASPs have long supported in a responsible and compliant manner."
"Ultimately, absent evidence that existing AML regulations cannot adequately address the risks posed by privacy coins, there is no reason to impose new and overbroad AML requirements that specifically target privacy coins."
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