New FATF Guidelines for DeFi: Control Over the Protocol and AML Obligations

This article reviews new FATF guidance addressing decentralized finance (DeFi) protocols and the associated AML obligations. It examines the criteria FATF uses to determine when a DeFi arrangement is considered sufficiently decentralized to fall outside traditional regulatory categories. The piece discusses implications for developers, operators and users of DeFi platforms. It also considers how the guidance may influence national implementations of AML rules for crypto markets.

  • FATF criteria for DeFi decentralization
  • AML obligations for DeFi protocol controllers
  • Implications for DeFi developers and operators
  • Expected impact on national crypto AML rules

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