Laws & enforcement

Law · withdrawnUnited States

FinCEN withdraws mixer and unhosted-wallet proposals

FinCEN withdrew its 2023 mixer rule and its 2020 unhosted-wallet reporting rule. Neither was ever made final.

Law · in forceUnited States

OFAC and FinCEN action on the A7 network

OFAC designated the Russia-linked A7 network behind the A7A5 rouble token. FinCEN proposed a ban on transfers involving its agents.

Law · proposedEuropean Union

AMLA draft rules on customer checks

AMLA sent the Commission its final draft customer due diligence rules under the AML Regulation, which also covers crypto providers.

Law · in forceJapan

Japan moves crypto under securities law (FIEA)

The Diet moved crypto trading under the Financial Instruments and Exchange Act. Unregistered crypto business now risks up to 10 years in prison.

Law · in forceEuropean Union

MiCA transition period ends

Crypto firms that served EU customers under national rules now need a MiCA licence to continue.

Law · in forceUnited States

OFAC designation of Nobitex and three Iranian exchanges

OFAC sanctioned Nobitex, Wallex, Bitpin and Ramzinex, Iran’s four largest crypto exchanges, over IRGC-linked transactions.

Law · in forceEuropean Union

EU ban on Russian crypto providers

The 20th package bans all transactions with crypto providers based in Russia, the RUBx token and the digital rouble.

Law · proposedUnited States

GENIUS Act AML rule for stablecoin issuers

Stablecoin issuers would need AML and sanctions programmes and the technical means to block, freeze and reject transfers.

Law · guidanceFATF

FATF report on stablecoins and unhosted wallets

FATF called peer-to-peer stablecoin transfers through unhosted wallets a key risk and urged issuers to be able to freeze coins.

Law · in forceUnited Arab Emirates

Dubai Travel Rule bans privacy-token transfers

VARA told Dubai VASPs not to execute transfers involving privacy tokens and to apply extra checks to unhosted wallets.

Law · in forceUnited Kingdom

UK cryptoasset regime (SI 2026/102)

Crypto firms come under FCA authorisation. The full regime starts on 25 October 2027.

Law · in forceBrazil

Brazil central bank VASP rules (mixers, self-custody)

Licensed VASPs may not use mixers or tumblers and must identify the owners of self-custody wallets they deal with.

Law · in forceEuropean Union

EU DAC8 crypto reporting begins

EU crypto providers must collect users’ tax details and report their transactions to tax authorities.

Law · in forceUnited Kingdom

UK crypto tax reporting (CARF)

UK crypto providers must collect users’ tax details and report their transactions to HMRC.

Law · withdrawnPoland

Poland crypto-asset market act vetoed

The president vetoed the bill, and two later versions in February and June 2026. The Sejm failed to override each veto.

Law · in forceEuropean Union

EU 19th sanctions package (A7A5 ban)

The EU banned transactions in the rouble stablecoin A7A5 and listed crypto platforms used to evade sanctions on Russia.

Law · in forceUnited States

FinCEN section 311 cut-off of Huione Group

US banks may not hold accounts for Cambodia’s Huione Group, which FinCEN says laundered at least $4 billion. A June 2026 proposal would add its successor H-Pay.

Law · guidanceUnited States

DOJ stance on non-custodial developers

DOJ said it will not approve new unlicensed money-transmitting charges against developers of truly decentralised, non-custodial software. Writing code without criminal intent is not a crime.

Law · in forceUnited Kingdom

UK sanctions on Grinex and the A7A5 network

The UK sanctioned the Grinex and Meer exchanges, the network behind the rouble token A7A5, and Kyrgyz Capital Bank.

Law · in forceUnited States

OFAC designation of Grinex (Garantex successor)

After the March 2025 Garantex domain seizure, OFAC designated Grinex and related executives as the successor cash-out rail.

Law · in forceUnited States

GENIUS Act (US payment stablecoins)

Federal/state licensing and 1:1 reserve rules for payment stablecoins, closing a path that some users treated as a KYC-light dollar rail.

Law · proposedUnited States

CLARITY Act (market structure)

The House passed the crypto market-structure bill 294–134. A Senate vote to start debate failed 49–50 on 15 September 2026.

Law · in forceSingapore

Singapore DTSP licensing (offshore-only firms)

Singapore firms serving only overseas crypto customers need a licence, which MAS says it will generally not grant.

Law · guidanceFATF

FATF revises Recommendation 16 (Travel Rule)

FATF set standard payer and payee details for payment messages, including virtual-asset transfers. Countries have until the end of 2030.

Law · guidanceUnited States

DOJ memo ending regulation by prosecution

The Deputy Attorney General told prosecutors to stop charging exchanges, mixers and offline wallets for their users’ crimes or unwitting regulatory breaches.

Law · in forceUnited States

OFAC delisting of Tornado Cash

Treasury removed Tornado Cash from the SDN list after review of the Van Loon litigation. Developer criminal cases are separate. Legal defence fundraiser for Roman Storm: https://freeromanstorm.com/donate

Law · in forceUnited States

US state money-transmitter acts (crypto)

State MTL/MTL-equivalent licenses (beyond NY BitLicense) are how many US ramps are forced into KYC even without a federal VASP statute.

Law · in forceEuropean Union

TFR unhosted-wallet CASP duties

From 30 Dec 2024 CASPs must collect originator/beneficiary info on self-hosted transfers above thresholds, the operational Travel Rule against mixers’ cash-out.

Law · in forceAustralia

Australia AML/CTF Tranche 2 expansion

From 31 March 2026, Australian VASPs face wider licensing and Travel Rule duties, including checks on transfers with self-hosted wallets.

Law · litigationUnited States

Van Loon v. Treasury (Fifth Circuit)

Fifth Circuit held OFAC could not treat immutable Tornado Cash smart contracts as property under IEEPA. Human-controlled entities remain fair game.

Law · in forceUnited Kingdom

UK Money Laundering Regulations (cryptoasset firms)

UK MLRs require cryptoasset exchange and custodian-wallet firms to register with the FCA and apply CDD, including Travel Rule implementation via JMLSG/FCA.

Law · in forceUnited States

IRS Form 1099-DA / broker reporting

Digital-asset broker reporting (Form 1099-DA) requires platforms to report customer proceeds, another identity rail beside BSA KYC.

Law · in forceTaiwan

Taiwan VASP AML rules (FSC)

FSC AML/CFT rules for virtual-asset platforms, including CDD and Travel Rule direction.

Law · in forceEuropean Union

MiCA Titles III–IV (ARTs/EMTs)

MiCA asset-referenced and e-money token rules with issuer KYC and reserve duties, shrinking anonymous euro-stablecoin issuance in the Union.

Law · guidanceFATF

FATF grey-list pressure on national VASP laws

Grey-listing is used to force Travel Rule and VASP licensing in lagging jurisdictions, which then show up as mixer-hostile local rules.

Law · in forceEuropean Union

EU Anti-Money Laundering Authority (AMLA)

Regulation establishing AMLA, the Union AML supervisor that will directly supervise selected high-risk obliged entities, including some crypto firms.

Law · in forceEuropean Union

EU AML Regulation (AMLR)

Single EU AML rulebook with tighter CDD, beneficial-ownership, and limits that affect cash-like and crypto anonymity in the Union.

Law · in forceEuropean Union

EU AMLR cash transaction cap

AMLR Union-wide cash payment cap (with member-state options) sits next to crypto CDD as a cash-like anonymity squeeze.

Law · proposedUnited States

FIT21 (House-passed market structure)

House-passed Financial Innovation and Technology for the 21st Century Act would split CFTC/SEC crypto market structure; not a mixer license, but a KYC-heavy exchange perimeter.

Law · litigationUnited States

DOJ theory in Samourai Wallet

Prosecutors charged wallet/mixing-tool developers as money transmitters. Both founders pleaded guilty in July 2025 and got 5 and 4 years in November 2025.

Law · in forceSingapore

MAS PSN02 AML notices (DPT)

MAS Notice PSN02-style AML/CFT for DPT service providers, including screening and Travel Rule.

Law · withdrawnEuropean Union

EU debate on anonymous self-custody caps

Parliament considered a €1,000-style cap on anonymous self-hosted transfers in the AML package; the strictest clause did not survive as originally drafted.

Law · in forceArgentina

Argentina UIF crypto reporting

UIF resolutions bringing virtual-asset providers into KYC and suspicious-operation reporting.

Law · guidanceUnited States

CSBS money-transmitter model (crypto)

Conference of State Bank Supervisors model language used by states to treat crypto transmission as MTL, forcing KYC at ramps.

Law · in forceCanada

FINTRAC Travel Rule for VASPs

Travel Rule obligations for Canadian virtual-currency dealers, including information on transfers.

Law · in forceHong Kong

Hong Kong VA Travel Rule circular

SFC circulars on originator/beneficiary information for licensed VA platforms.

Law · in forceSingapore

MAS Travel Rule notices for DPT

MAS notices implementing originator/beneficiary information for digital payment token transfers.

Law · in forceNigeria

Nigeria VASP Act (mixer restrictions)

VASP licensing with AML/CFT; public summaries describe mixer activity as prohibited for licensed providers.

Law · in forceUnited States

OFAC designation of Sinbad.io

Follow-on mixer designation after Blender, pairing Treasury listing with European infrastructure seizures.

Law · guidanceOECD

IOSCO policy recommendations for crypto

IOSCO crypto and digital-asset recommendations press securities regulators toward KYC’d platforms.

Law · in forceUnited Kingdom

UK Economic Crime and Corporate Transparency Act

Companies-house identity, crypto seizure, and failure-to-prevent fraud provisions used alongside MLRs.

Law · withdrawnUnited States

FinCEN NPRM on CVC mixing

Proposed rule would have made transactions involving CVC mixing a reporting event. FinCEN withdrew it on 5 October 2026.

Law · in forceEuropean Union

EU DAC8 crypto tax reporting

DAC8 extends automatic tax-information exchange to crypto-asset service providers, another deanonymizing reporting rail alongside Travel Rule.

Law · in forceUnited Kingdom

UK Travel Rule (cryptoasset transfers)

FCA/JMLSG Travel Rule for UK cryptoasset firms, including unhosted-wallet collection above thresholds.

Law · litigationUnited States

DOJ case against Roman Storm (Tornado Cash)

SDNY charged a Tornado Cash developer. A 2025 jury convicted him of an unlicensed money-transmitting conspiracy; the laundering and sanctions counts face a retrial set for April 2027. Defence fund: https://freeromanstorm.com/donate

Law · guidanceUnited States

FinCEN CVC kiosk (ATM) proposal / alerts

FinCEN treats CVC kiosks, a cash-to-crypto rail, as money transmitters. An August 2025 notice listed red flags for kiosk scam payments.

Law · guidanceFATF

FATF DeFi / unhosted wallet language

FATF’s updates discuss when a DeFi ‘controller’ is a VASP, the theory used to pressure front-ends and coordinators.

Law · guidanceFATF

FATF targeted update on VA implementation

FATF’s targeted update pressed jurisdictions that had not enforced Travel Rule or VASP licensing, naming mixers and DeFi interfaces as residual risk.

Law · in forceHong Kong

Hong Kong VASP licensing (AMLO)

SFC licensing for VA trading platforms under the Anti-Money Laundering Ordinance, with Travel Rule and retail-investor gating.

Law · in forceJapan

Japan Travel Rule (JVCEA)

JVCEA-mandated Travel Rule among registered CASPs, with unhosted-wallet extra checks.

Law · in forceEuropean Union

EU Markets in Crypto-Assets (MiCA)

Union-wide crypto-asset service provider licensing, with AML hooks and stablecoin issuer rules that squeeze anonymous issuance and transfer.

Law · in forceEuropean Union

EU Transfer of Funds Regulation (TFR)

Applies FATF Travel Rule to crypto-asset transfers in the EU, including information accompanying transfers to and from self-hosted wallets above thresholds.

Law · in forceSouth Africa

South Africa FICA Schedule 1 VASPs

Crypto asset service providers added as accountable institutions under FICA, with FIC reporting.

Law · in forceUnited States

FinCEN 9714 order on Bitzlato

FinCEN identified Bitzlato as a primary money-laundering concern under the Combating Russian Money Laundering Act, alongside the DOJ arrest.

Law · in forceChile

Chile Fintech Law (crypto)

Comisión para el Mercado Financiero fintech/crypto perimeter with UAF AML.

Law · in forceGeorgia

Georgia NBG VASP rules

National Bank of Georgia virtual-asset service provider rules with AML.

Law · proposedPeru

Peru SBS virtual-asset bill / UIF

SBS/UIF work on virtual-asset AML registration; not a full license in all drafts.

Law · in forceUnited Arab Emirates

UAE federal VA AML (CBUAE/SCA)

Federal virtual-asset AML and licensing through CBUAE and SCA alongside DIFC/ADGM regimes.

Law · in forceBrazil

Brazil crypto AML law (14.478/2022)

Federal crypto-asset law placing VASPs under BCB/CVM with AML via COAF.

Law · guidanceFATF

Basel crypto prudential standard

Basel Committee prudential treatment of cryptoasset exposures, pushing banks away from unhosted and mixed flows.

Law · liftedUnited States

OFAC redesignation of Tornado Cash

November 2022 redesignation added more Tornado-related addresses. Removed with the March 2025 delisting; kept for the 2022–2025 record.

Law · in forceUnited Arab Emirates

DIFC DFSA crypto token regime

DIFC crypto-token rules ban privacy tokens and privacy devices such as mixers. Revised rules from 12 January 2026 keep the ban.

Law · in forceLithuania

Lithuania crypto AML amendments

Tighter Lithuanian AML rules for virtual-asset service providers, including Travel Rule preparation.

Law · in forceOECD

OECD Crypto-Asset Reporting Framework (CARF)

OECD standard for automatic exchange of crypto-asset user and transaction data among tax authorities. Reporting began in 2026 in 46 jurisdictions; 27 more follow in 2027.

Law · guidanceSouth Africa

SARB/IFWG crypto-asset framework

Intergovernmental Fintech Working Group framework leading into FICA Schedule 1 VASP status.

Law · guidanceUnited States

OFAC FAQs on Tornado / smart-contract sanctions

OFAC FAQs on interacting with sanctioned mixer addresses, including open-source publication and wallet screening. Still relevant after delisting for other SDN mixers.

Law · liftedUnited States

OFAC designation of Tornado Cash

Treasury designated a non-custodial mixer on 8 Aug 2022, using IEEPA/OFAC rather than BSA licensing. The SDN listing was removed on 21 Mar 2025; the 2022 action remains part of the record.

Law · in forceAustralia

Australia AUSTRAC DCE registration

Digital currency exchanges must enroll with AUSTRAC, apply KYC, and report under the AML/CTF Act.

Law · in forceUnited States

OFAC designation of Blender.io

First OFAC mixer designation, citing DPRK-linked laundering. Established mixers as sanctions targets, not only MSBs.

Law · in forceUnited States

OFAC designation of Garantex (with Hydra)

Treasury designated Hydra Market and Garantex the same day, treating a darknet market and its cash-out exchange as one AML problem.

Law · in forceEstonia

Estonia crypto license tightening

Estonia raised capital, residency, and AML bars for crypto licenses after earlier light-touch registration was abused.

Law · in forceUnited Arab Emirates

Dubai VARA virtual-asset regime

Dubai Virtual Assets Regulatory Authority licensing with AML/CFT rulebooks. Mixers are not a permitted activity.

Law · in forceIndia

India PMLA / FIU-IND VDA reporting

Virtual digital assets brought under PMLA; exchanges must KYC, report to FIU-IND, and apply 30% tax plus TDS that deanonymizes on-ramps.

Law · in forceUnited Kingdom

UK Russia (Sanctions) crypto provisions

UK Russia sanctions regulations include crypto-asset reporting and freeze duties for UK VASPs.

Law · in forceEuropean Union

EU restrictive measures (Russia) + crypto

EU Russia sanctions packages include crypto-wallet and transfer restrictions that also hit mixer cash-out into the Union.

Law · in forceUkraine

Ukraine virtual-asset law

Law on Virtual Assets (implementation staggered with wartime NSSMC/NBU rules) plus AML via SFMS.

Law · withdrawnCanada

Canada Emergencies Act / crypto freeze (2022)

2022 Emergencies Act orders included crypto-fundraising freezes. The Act invocation ended; the episode is kept as a self-custody-risk precedent.

Law · guidanceColombia

Colombia SFC crypto sandbox / UIAF

SFC pilots plus UIAF SAR reporting for platforms; national VASP license still evolving.

Law · in forceHungary

Hungary MNB crypto AML

MNB/NAV AML expectations for virtual-asset service providers.

Law · in forceItaly

Italy OAM crypto register

Organismo Agenti e Mediatori register for virtual-currency operators plus UIF reporting.

Law · in forceJapan

Japan APPI + crypto KYC stack

Payment Services Act plus APPI data rules and JVCEA Travel Rule together make Japanese ramps among the least mixer-friendly.

Law · in forceKazakhstan

Kazakhstan AIFC / AFSA crypto

AIFC AFSA crypto-exchange framework with AML, while the rest of Kazakhstan has tighter National Bank limits.

Law · guidanceKuwait

Kuwait CBK crypto circulars

Central Bank circulars warning against crypto dealing; AML Law still used for related investigations.

Law · in forceNigeria

Nigeria SEC digital-asset rules

SEC digital-asset offering and exchange rules alongside CBN banking restrictions and the later VASP Act.

Law · in forceQatar

Qatar crypto restrictions + QFC AML

Retail crypto activity heavily restricted; QFC/QCB AML still applies to licensed financial firms touching VA.

Law · guidanceUnited Kingdom

UK OFSI crypto sanctions guidance

OFSI guidance on virtual-currency sanctions compliance, used when UK persons touch OFAC/UK-listed mixer addresses.

Law · guidanceFATF

Wolfsberg FAQs on VAs

Correspondent-bank Wolfsberg Group FAQs push banks to treat mixer exposure as high-risk, which is why ramps freeze mixed coins even without a mixer ban.

Law · in forceUnited States

OFAC designation of Chatex

Nested exchange designated as a ransomware cash-out rail tied to Suex.

Law · in forcePoland

Poland AML Act crypto register

Polish AML Act register of virtual-currency activities with GIIF reporting.

Law · guidanceFATF

FATF updated RBA guidance for VA/VASPs

Updated risk-based guidance highlights mixers, tumbling, P2P, and unhosted wallets as higher-risk typologies for national assessments.

Law · in forceChina

China virtual-currency ban (PBOC notice)

PBOC and co-regulators declared virtual-currency business illegal, including related exchange and facilitation, pushing remaining activity offshore.

Law · in forcePortugal

Portugal BdP crypto registration

Banco de Portugal registration of virtual-asset service providers with AML.

Law · in forceSouth Korea

South Korea VASP / Travel Rule (FIU, FSC)

Real-name bank accounts for VASPs plus Travel Rule implementation that blocks many unhosted-wallet deposits without extra checks.

Law · in forceUnited States

OFAC designation of Suex OTC

First OFAC designation of a virtual-currency exchange, for laundering ransomware proceeds. Template for later Garantex/Chatex actions.

Law · in forceEl Salvador

El Salvador Bitcoin Law

Legal-tender bitcoin law is not a mixer ban, but Chivo/KYC ramps and later IMF-linked adjustments affect how private bitcoin is spent onshore.

Law · in forceSwitzerland

Switzerland AMLA / DLT Act VASPs

FINMA-supervised DLT trading and AMLA due diligence for VASPs; Travel Rule via SRO/VQF practice, including unhosted wallets.

Law · in forceRomania

Romania ONPCSB crypto reporting

ONPCSB AML reporting for virtual-currency exchangers.

Law · in forceEuropean Union

EU 6AMLD (Directive (EU) 2018/1673)

Sixth AML directive expanded predicate offences and liability, used alongside 5AMLD for crypto-related laundering cases.

Law · in forceGreece

Greece Bank of Greece VASP

Bank of Greece crypto-exchange and custody registration under AML law.

Law · in forceTurkey

Turkey crypto AML (MASAK) + payment ban

MASAK KYC for crypto platforms plus the 2021 ban on using crypto as payment, squeezing on-chain anonymity at ramps.

Law · litigationUnited States

Bitcoin Fog / Sterlingov case

Mixer operator convicted of laundering and unlicensed money transmission and sentenced to 150 months. The D.C. Circuit upheld the convictions in September 2026.

Law · in forceSpain

Spain crypto AML registration (SEPBLAC/CNMV)

Spanish AML law registration for crypto exchange and custody with SEPBLAC/Bank of Spain/CNMV.

Law · in forceIreland

Ireland CBI VASP registration

Central Bank of Ireland VASP registration under the Criminal Justice (Money Laundering) Act.

Law · in forceIndonesia

Indonesia crypto commodity / AML

Bappebti then OJK-era crypto trading rules with PPATK AML reporting.

Law · in forcePhilippines

Philippines BSP VASP guidelines

BSP virtual-asset service provider guidelines with KYC, Travel Rule direction, and caps.

Law · in forceCzechia

Czech AML Act crypto persons

FAÚ/CNB perimeter for persons providing virtual-asset services, with AML Act CDD.

Law · in forceIsrael

Israel ISA / Prohibition on Money Laundering (crypto)

Israeli crypto service provider licensing with IMPA reporting and Travel Rule direction.

Law · guidanceKenya

Kenya CMA crypto caution / AML

CMA/CBK cautions plus Proceeds of Crime and AML Act reporting for VASPs as policy develops.

Law · in forceRussia

Russia 115-FZ / digital-asset AML

AML law and digital-financial-asset statutes; enforcement is uneven, but KYC is required for licensed ramps.

Law · guidanceSaudi Arabia

Saudi SAMA / CMA crypto caution + AML

SAMA/CMA statements restricting unlicensed crypto activity while AML Law still captures related reporting.

Law · in forceSlovakia

Slovakia NBS crypto AML

Národná banka Slovenska / FSJ AML obligations for virtual-currency providers.

Law · guidanceVietnam

Vietnam SBV crypto caution / AML Law 2022

SBV circulars treating crypto as not legal tender plus the 2022 AML Law reporting perimeter. Licensing remains in flux.

Law · in forceBahamas

Bahamas DARE / DARE 2020

Digital Assets and Registered Exchanges Act licensing VASPs with AML via the Compliance Commission/CBB.

Law · in forceCayman Islands

Cayman VASP Act

CIMA virtual-asset service provider registration with AML regulations.

Law · in forceBelgium

Belgium NBB crypto registration

National Bank of Belgium registration for exchange and custody providers.

Law · in forceCanada

Canada PCMLTFA (dealers in virtual currency)

FINTRAC treats virtual-currency dealers as money-services businesses with KYC, recordkeeping, and large-transaction reporting. Date of crypto amendments; statute is older.

Law · in forceNetherlands

Netherlands Wwft crypto registration

DNB registration for crypto service providers under Wwft, with CDD and reporting. FIOD mixer cases sit outside this perimeter.

Law · in forceSouth Korea

Korea Specific Financial Information Act (crypto)

Amended SFIA brought virtual-asset service providers under FIU reporting and real-name accounts.

Law · in forceSingapore

MAS Payment Services Act (DPT)

Digital payment token services require a license, CDD, and Travel Rule compliance — mixers are outside the licensed perimeter.

Law · in forceMalaysia

Malaysia SC capital-markets crypto + AML

Securities Commission digital-asset exchange recognition with AMLA reporting to Bank Negara.

Law · in forceAustria

Austria FMA VASP registration

FMA registration under FM-GwG for virtual-asset service providers.

Law · in forceEuropean Union

EU 5AMLD (Directive (EU) 2018/843)

Brought virtual-currency exchange and custodian-wallet providers into EU AML/CFT, with customer due diligence and register obligations.

Law · in forceBulgaria

Bulgaria crypto AML (FID)

Bulgarian FID AML Act obligations for virtual-currency service providers.

Law · in forceCroatia

Croatia HANFA/AMLO crypto

Croatian AML Act registration for virtual-asset services.

Law · in forceEgypt

Egypt CBE crypto prohibition

CBE prohibition on crypto dealing without license, with AML Law 80/2002 still the reporting backbone.

Law · in forceGermany

Germany GwG + BaFin crypto custody

Crypto custody became a licensed BaFin activity from 2020; GwG CDD applies, leaving mixers outside the licensed set.

Law · in forceIceland

Iceland crypto AML

Central Bank / FSA perimeter for virtual-asset services under AML Act.

Law · in forceGermany

KWG crypto-custody permission (Germany)

Kreditwesengesetz amendment requiring permission for crypto custody business in Germany.

Law · in forceLiechtenstein

Liechtenstein TVTG (Blockchain Act)

Token and TT Service Provider Act licenses token service providers with AML hooks; mixers are not a licensed TT service.

Law · in forceSlovenia

Slovenia crypto AML (ATVP/OMLP)

Slovenian AML Act virtual-currency provider registration.

Law · litigationUnited States

Helix / Larry Harmon BSA case

DOJ charged Helix’s operator as an unlicensed money transmitter. He got 36 months in 2024, and over $400M was forfeited in January 2026.

Law · in forceNew Zealand

New Zealand AML/CFT (virtual asset)

DIA/FMA treat virtual-asset service providers as reporting entities under AML/CFT Act.

Law · in forceFATF

FATF Recommendation 16 (Travel Rule) for VASPs

Updated R.16 requires VASPs to collect and transmit originator and beneficiary information on transfers, the main global driver of KYC on crypto rails.

Law · in forceFrance

France PACTE / PSAN registration

Digital-asset service provider (PSAN) registration with AMF/ACPR and AML/CFT via Tracfin.

Law · guidanceUnited States

FinCEN CVC kiosk / mixing FAQ update

FinCEN restated that CVC mixing, tumbling, and kiosk operators that accept and transmit value can be money transmitters even without holding keys in a classic bank sense.

Law · in forceFinland

Finland FIN-FSA crypto registration

FIN-FSA registration of virtual-currency providers under the AML Act.

Law · in forceDenmark

Denmark FSA crypto AML

Danish FSA registration of virtual-currency providers under the AML Act.

Law · guidanceSwitzerland

FINMA Travel Rule guidance (unhosted wallets)

FINMA’s strict Travel Rule interpretation, including identifying unhosted-wallet counterparties, was an early national implementation.

Law · in forceAustralia

Australia TOLA / Industry Assistance

Telecommunications and Other Legislation Amendment (Assistance and Access) Act is the decryption-capability statute often cited next to AML for device/wallet access debates.

Law · in forceMalta

Malta Virtual Financial Assets Act

MFSA VFA licensing with AML/CFT via FIAU; one of the first EU national crypto-license statutes.

Law · in forceFATF

FATF Recommendation 15 (virtual assets)

FATF extended AML/CFT standards to virtual assets and VASPs, the hook later used for Travel Rule and mixer risk language.

Law · in forceNorway

Norway FSA crypto register

Finanstilsynet registration for exchange and custody with Money Laundering Act CDD.

Law · in forceUnited Arab Emirates

ADGM FSRA crypto framework

Abu Dhabi Global Market financial-services crypto licensing with FATF-aligned AML.

Law · in forceThailand

Thailand Emergency Decree on Digital Asset Businesses

SEC licensing for digital-asset businesses with AMLO KYC. Unlicensed mixer activity is outside the decree’s licensed set.

Law · in forceBelarus

Belarus Decree No. 8 (HTP crypto)

HTP legalizes certain crypto activities with AML via Decree 8; mixers are not the licensed product.

Law · in forceMexico

Mexico Fintech Law (ITF)

Ley para Regular las Instituciones de Tecnología Financiera licenses ITFs with CNBV/UIF KYC; virtual assets tightly gated.

Law · in forceBermuda

Bermuda Digital Asset Business Act

BMA digital-asset business licenses with AML/ATF; mixer operation is not a licensed activity.

Law · in forceGibraltar

Gibraltar DLT framework

GFSC DLT provider framework with AML/CFT; mixers not in scope as licensed DLT activity.

Law · in forceSweden

Sweden FSA crypto registration

Finansinspektionen currency-exchange style registration for crypto firms plus FI reporting.

Law · in forceUnited Kingdom

UK MLRs 2017 (as amended for crypto)

The 2017 MLRs, amended in 2019, brought cryptoasset exchange and custodian wallet firms into FCA registration and CDD.

Law · in forceJapan

Japan Payment Services Act (crypto exchanges)

JVCEA/FSA registration, KYC, and Travel Rule among early national VASP regimes after Mt. Gox.

Law · in forceUnited Kingdom

UK Investigatory Powers Act (bulk / equipment)

Investigatory Powers Act equipment-interference and bulk powers sit behind many UK crypto investigations even when the charging statute is MLRs.

Law · in forceUnited States

US CISA / later cyber sharing

Cybersecurity information-sharing statutes plus later CIRCIA-style reporting increase how mixer-related incidents flow to Treasury/FBI.

Law · in forceUnited States

NYDFS BitLicense (23 NYCRR 200)

New York’s virtual-currency license requires KYC, BSA-style AML, and cybersecurity for firms serving NY residents. Anonymous mixer operation is outside the licensed set.

Law · in forceEuropean Union

EU 4AMLD (Directive (EU) 2015/849)

Fourth AML directive set Union CDD, beneficial-ownership, and obliged-entity rules later extended to crypto.

Law · in forceUnited States

FinCEN guidance on convertible virtual currency

FinCEN treats administrators and exchangers of convertible virtual currency, including mixing-type money transmission, as money transmitters under the BSA.

Law · in forceUnited States

USA PATRIOT Act §311 / 359

Patriot Act expanded BSA money-transmitter definitions and special measures later used on foreign VASPs (e.g. Bitzlato 9714).

Law · in forceUnited Nations

UNTOC / Palermo (predicate AML)

UN Convention against Transnational Organized Crime underpins many national mixer-laundering prosecutions as predicate-offence AML.

Law · in forceUnited States

IEEPA (sanctions authority used on mixers)

International Emergency Economic Powers Act is the statute OFAC used to list mixers and VASPs. Van Loon limited its use against immutable smart contracts.

Law · in forceUnited States

Bank Secrecy Act

The BSA is the US AML backbone. FinCEN later applied it to convertible virtual currency administrators and exchangers, which is why mixer operators are charged as unlicensed money transmitters.