If you haven’t read @USTreasury report on money laundering in #art world, do so this weekend. #NFTs in clear sight - and not just digital art! First (?) step to #FinCEN rules requiring #KYC and much more under the #BSA. @CoinDesk summary flawless. But read the rest. 1/7
@USTreasury report puts #NFTs in full view of policymakers. Not just #artNFTs. We predicted this focus a year ago as well as focus on issue of “innocent” #artist receiving “dirty money” royalties on resale - which is flagged in this report. 2/7
@USTreasury says some NFT platforms may already be subject to FinCEN rules “depending on the characteristics of the NFTs that they offer.” Not limited to, and not excluding #artNFTs. Immediate compliance obligations - no if and when @SEC finishes its exchange rules. 3/7
@USTreasury notes criminals are selling - and buying their own works to launder funds (yes crypto is “funds” for this purpose). No coincidence that @chainalysis released a report on wash trades. Important read. 4/7 blog.chainalysis.com/reports/2022-c…
For #NFT #marketplaces this focus should not make a difference as they already are subject to federal criminal statutes prohibiting them from engaging in, aiding and abetting or being willfully blind to #moneylaundering. 5/7
#NFT platforms mitigate risk of criminal abuse and prosecution for criminal activity on the platform with #AML programs, #KYC and active steps to detect, report and prevent abuse. (See @DOJ guidelines). 6/7
Today’s predictions: Expect more active steps from #NFT #platforms. More #KYC and other steps that may not be welcomed in #crypto world. But as businesses they need to protect themselves. Those that don’t will be likely candidates for enforcement/prosecutions. Wash traders? 7/7

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