Problems in the Revised FATF Standard - Part 2

（3） Stable currency

The revised FATF Standard brings the stable currency into the adjustment range and believes that it may be a virtual asset or a traditional financial asset. FATF believes that if all regions have fully implemented the revised FATF Standard, the current standard is sufficient to reduce the capital flow risk caused by the stable currency. Nevertheless, FATF claims that this field must be strictly regulated, because it’s still common for the residual risk caused by stabilizing currency through peer-to-peer transactions, weak supervision of "anti-money-laundering" and decentralized governance. At the same time, the landing of the stable currency poses a great challenge to the skill and expertise of the regulatory authorities.

（4） Implementation of the Travel Rule

The "Travel Rule" was first proposed by the U.S. financial crime enforcement network (FinCEN) in 1996. In March 2013, the rules were extended to cryptocurrency exchanges。The "Travel Rule" requires cryptocurrency exchanges in all jurisdictions to fulfill the obligation of "KYC (know your customer)", and stipulates that VASP must share the information when the sender and receiver exceed a specific threshold, and properly keep the relevant information for the authorities’ money laundering and terrorist financing review.

There are several different technical solutions for Travel Rule under development, some of which are being released or tested. However, it may take a few years for "Travel Rules" to be widely used. Under the "Travel Rule", the cryptocurrency in the "White List" is subject to more strict control, while the cryptocurrency in the "Grey Market" will be issued and circulated in another way away from the traditional trading ecosystem. Market differentiation will make it difficult to realize effective exchange between cryptocurrencies, and then affect the "interactivity" of tokens.