The Role of Anti–Money Laundering Law and Compliance in FinTech

Currently, some FinTechs are innovating in financial services in a vacuum, often providing financial services without understanding or complying with anti‐money laundering (AML) and counterterrorist financing (CTF) laws. FinTechs that provide financial services without understanding and complying with AML/CTF laws as applicable will be inhibited in their ability to scale, particularly as financial crime controls are increasing. Sanctions law is an important but often overlooked part of AML/CTF compliance. Sanctions laws are national. They prohibit financial transactions for certain sanctioned persons, entities, and countries. Sanctions avoidance is a predicate offence for money laundering, and therefore the proceeds of sanctions avoidance are the proceeds of crime. The US Office of Foreign Assets Control remains the most important agency in the world in respect of sanctions that FinTechs, no matter where they operate, need to be familiar with.