13 Aug 2025
Crypto doesn’t live on an island. Every scam payout, darknet-market sale, or cross-border transfer eventually touches a bank account, a payment processor, a card, a kiosk, or a securities venue. That “touchpoint"
Crypto doesn’t live on an island. Every scam payout, darknet-market sale, or cross-border transfer eventually touches a bank account, a payment processor, a card, a kiosk, or a securities venue. That “touchpoint” is where crypto AML meets the traditional financial system. As adoption widens, these touchpoints multiply—and the rules in India, the US, and the UK are converging toward the same idea: same activity, same risk, same rules.
The plumbing: how crypto value enters and exits “TradFi”
On/Off-ramps
Centralized exchanges, brokerages, and P2P platforms convert INR/USD/GBP ↔ crypto, relying on bank rails and card networks. These are now regulated like money transmitters/MSBs (US), VASP/Reporting Entities (India), or cryptoasset businesses under the UK’s MLRs.
Payment and settlement
Fiat settlements after a crypto trade clear through banks or EMI institutions; Travel Rule data is increasingly required on crypto transfers—mirroring wire-transfer rules. The UK made this explicit from 1 September 2023; more countries are aligning.
Risk spillover
When crypto funds linked to mixing, ransomware, or sanctioned actors try to cash out, banks see elevated AML flags. The US has pushed new reporting on “CVC mixing” (tumbling/obfuscation), treating it as a primary money laundering concern and proposing recordkeeping/reporting duties on covered financial institutions.
India: FIU brings VASPs inside the AML perimeter
Since March–July 2023, Virtual Digital Asset service providers are “Reporting Entities” under the PMLA. They must register with FIU-IND, do KYC, keep records, and file STRs—just like other regulated financial players.
Enforcement has teeth: in 2024, FIU fined Binance ₹188.2m for AML breaches tied to operating without proper registration (after earlier show-cause notices and blocking moves). Follow-on actions hit other offshore platforms as well.
FATF’s 2024 mutual evaluation underlines India’s push to implement VA/VASP standards; banks and payments firms are expected to manage crypto exposure in line with those risks.
Why this links to TradFi: Indian banks/payment partners servicing VASPs must map Travel Rule readiness, sanction screening, and wallet-risk signals into their AML programs; otherwise they inherit VASP risk through settlements and merchant flows.
United States: BSA obligations + mixing crackdown
FinCEN’s guidance (2013, consolidated in 2019) treats administrators/exchangers of convertible virtual currency as money services businesses under the Bank Secrecy Act—requiring registration, AML programs, and SAR filing. Banks must treat crypto exposure like any other higher-risk MSB relationship.
New focus: CVC mixing. Treasury/FinCEN proposed special measures in late 2023 to force visibility where obfuscation services hide source/destination of funds—directly impacting bank monitoring when mixed coins hit fiat rails.
FinCEN continues to issue alerts (kiosks, scams, terrorism financing) that push obligations onto both VASPs and traditional FIs.
Why this links to TradFi: US banks, card programs, and ATM/kiosk operators become “last-mile” controls—screening for mixers, darknet clusters, and sanctioned wallets before fiat payout.
United Kingdom: MLR registration, Travel Rule, and promotions regime
UK cryptoasset businesses must register with the FCA under the Money Laundering Regulations (MLRs) and comply with AML controls that echo those for payments and e-money firms.
Travel Rule: from 1 September 2023, UK firms must collect, verify, and transmit sender/recipient data with crypto transfers—harmonizing crypto transfers with bank wires.
Financial promotions: since October 2023, marketing crypto to UK consumers is covered by strict “clear, fair, not misleading” rules, affecting banks, fintechs, and platforms that distribute or white-label crypto. FCA has been actively reviewing compliance.
Why this links to TradFi: UK banks and brokers offering fiat on-ramps or ETN exposure must ensure counterparties meet AML/Travel Rule standards, and that promotions routed through their channels meet FCA rules—otherwise they inherit regulatory liability.
Darknets: the practical bridge from crypto to cash
Darknet markets (DNMs) still settle largely in crypto, but the cash-out lands in banks, P2P payment apps, or money mules. Chainalysis reports show darknet/fraud-shop flows in the low-billions annually, with year-to-year shifts as law-enforcement takedowns occur.
Illicit crypto flows are increasingly stablecoin-heavy (liquidity, price stability), while Bitcoin remains prominent on DNMs. This matters because stablecoin redemptions and issuer blacklisting can create clear, bank-visible choke points.
Criminal ecosystems (from pig-butchering scams to brokered “laundering-as-a-service”) use Telegram/OTC brokers and fiat ramps worldwide—including corporate entities registered in Western jurisdictions—before payouts hit traditional rails.
What “more linkage” looks like as adoption grows
Travel Rule everywhere: Expect expanded implementation and tech-neutral upgrades to FATF Recommendation 16 that pull crypto transfers even closer to wire-transfer norms. Banks will see richer originator/beneficiary data from VASPs and will be expected to use it.
Fusion of alerts: FinCEN/FIU/FCA advisories increasingly reference the same typologies (mixers, ransomware, OTC brokers), so bank AML and VASP AML will run on near-identical red-flag libraries.
Market-structure overlap: UK retail ETNs and US/other spot-product growth pull crypto exposures into brokerage and clearing workflows; sanctions/screening expectations will follow the asset, not the label.
Issuer and off-ramp controls: As stablecoin and exchange issuers expand banking relationships, expect more account-level freezes/blacklisting and more SARs at redemption/cash-out points. (Inference based on issuer actions and regulator direction of travel.)
Practical playbook for compliance teams (banks, fintechs, VASPs)
Common core (all three jurisdictions):
KYB on VASP counterparties: verify registration (FIU-IND, FCA MLRs, FinCEN MSB), licit geographies, Travel Rule capability.
Wallet screening & clustering: flag exposure to mixers, sanctioned services, darknet clusters, scam typologies, and ransomware tags; feed hits into customer and transaction risk scoring.
Travel Rule interoperability: require counterparties to send/receive originator/beneficiary data; reject/hold when mandatory fields are missing (UK already requires this).
Enhanced monitoring on off-ramps: high-velocity fiat withdrawals after on-chain obfuscation or DNM exposure should trigger EDD and potential SAR/STR.
India-specific:
Confirm FIU-IND registration for every VDA partner; align reporting (STRs, CTRs) to FIU formats; monitor enforcement updates and penalty orders (e.g., Binance, Bybit) for precedent.
US-specific:
Treat VASPs as MSBs under BSA; implement SAR models that recognize CVC mixing indicators and FinCEN advisories (including kiosk fraud and terror-finance alerts).
UK-specific:
Verify FCA MLR registration; audit Travel Rule controls; ensure any UK-facing promotions meet content, approval, and cooling-off rules (post-Oct 2023).
Bottom line
Crypto and traditional finance are already intertwined at every on/off-ramp, settlement, and product-distribution layer. India (FIU-IND under PMLA), the US (FinCEN/BSA), and the UK (FCA/MLRs + Travel Rule + promotions) are closing the gaps so that AML responsibilities look and feel the same on both sides of the bridge. As adoption increases—stablecoins in commerce, retail market products, cross-border payroll—the AML perimeter expands with it, and so will expectations on banks, PSPs, brokers, and VASPs to share data, spot obfuscation, and stop illicit cash-outs.
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