Crypto-asset licensees relying solely on the public information available on the blockchain or other type of distributed ledger underlying the accepted crypto-asset for record keeping in not sufficient for compliance with AML-6.1.1 and AML-6.1.1A. The information available on the blockchain or other type of distributed ledger may enable to trace transactions back to a wallet, though may not readily link the wallet address to the name of the customer and the beneficial owner. Crypto-asset licensees must ensure that additional information necessary to associate the wallet address to a natural person is maintained.
Added: January 2020