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AML-2A.2.11

The CBB recognises that unlike traditional fiat currency wire transfer, not every accepted crypto-asset transfer involves (or is bookended by) two institutions (crypto-asset entities or financial institution). In instances in which an accepted crypto-asset transfer involves only one financial institution on either end of the transfer (e.g. when an ordering financial institution sends accepted crypto-assets on behalf of its customers, the originator, to a beneficiary that is not a customer of a beneficiary financial institution but rather an individual user who receives the accepted crypto-asset transfer using his/her own distributed ledger technology (DLT) software, such as an unhosted wallet), the financial institution must still ensure adherence to Paragraph AML-2A.2.7 for their customer. The CBB does not expect that financial institutions, when originating an accepted crypto-asset transfer, would submit the required information to individual users who are not financial institutions. However, financial institutions receiving an accepted crypto-asset transfer from an entity that is not a financial institution (e.g. from an individual accepted crypto-asset user using his/her own DLT software, such as an unhosted wallet), must obtain the required originator information from their customer.

Added: January 2020