https://www.perkinscoie.com/images/content/2/3/v3/237411/Perkins-Coie-LLP-White-Paper-AML-Regulation-of-Privacy-enablin.pdf
that were developed to protect the financial privacy of individuals and businesses alike. Each privacy coin leverages
innovative mechanisms that provide privacy, encryption, and security to its users. Alongside their positive effects,
however, these mechanisms have raised an important compliance question:
Is it possible for regulated entities to comply with anti-money laundering (“AML”) obligations when supporting
privacy coins?
The answer, in our view, is yes.
Not only do privacy coins provide public benefits that substantially outweigh their risks, existing AML
regulations properly and sufficiently cover those risks, providing a proven framework for combatting money
laundering and related crimes.
In reaching that conclusion, we profile several privacy coins, detail key AML regulations and intergovernmental
recommendations affecting privacy coins, and explain the measures that have allowed financial institutions,
intermediaries, and virtual asset service providers (collectively, “VASPs”) to comply with AML obligations
when facilitating privacy coin transactions. We also dispel the misconception that privacy coins are
fundamentally incompatible with AML compliance, focusing on measures that have allowed VASPs to comply
with AML obligations when conducting or facilitating privacy coin transactions.