BAS’s Response to the Public consultation on FATF draft guidance on a risk-based approach to virtual assets and virtual asset service providers

BAS-Response-to-FATF-Paper-20-Apr-2021-Final-1.pdf (566 downloads )

  1. The Blockchain Association of Singapore (“BAS”) is an industry body whose mission is
    to be the leading industry organisation for the advocacy, collaboration, convergence,
    and fair use of blockchain and scalable technologies in Singapore, which has a vibrant
    blockchain community.
  1. Our members include Virtual Asset Service Providers (“VASPs”) (cryptocurrency
    exchanges, digital asset exchanges, custodial providers, OTC platforms, most of which
    are regulated in Singapore under the Payment Services Act), blockchain-based
    enterprises, academia, RegTech providers and professional consultancy firms.
  2. BAS’ Regulatory and Compliance Sub-Committee had organised a Webinar on 1 Apr
    2021 attracting 247 registrants, attended by around 214 participants from about 156
    companies. This set of submissions crystallizes some of the comments received during
    the Webinar.
  3. A panel of the Sub-Committee members, comprising former regulators and
    compliance thought leaders from the community, had led discussion of issues during
    the Webinar.
  4. At the outset, we would like to reiterate that BAS is committed to ensure upholding of
    robust and risk-appropriate standards of Anti-Moneylaundering (“AML”) and
    Combating the Financing of Terrorism (“CFT”) for the blockchain industry and is
    generally supportive of greater clarity on international prescriptions for AML/CFT
    compliance. For instance, we have conducted various webinars for our members to
    promote AML/CFT compliance, including a session relating to FATF’s Virtual Assets
    Red Flags Indicators of Money Laundering and Terrorist Financing (Sep 2020).