Strengthening AML and sanctions controls in the digital assets era
Abstract
This paper explores the anti-money laundering (AML) and sanctions regulatory environment for digital assets in the US, with particular emphasis on the emerging digital asset policy framework under the current presidential administration. The paper considers the principal illicit finance risks presented by digital asset activities and addresses key implications for AML and sanctions compliance controls for both digital asset firms and traditional financial institutions entering the digital asset ecosystem. Although US authorities have endorsed a more supportive approach to innovation and digital asset activities, regulators have simultaneously reaffirmed the importance of AML and sanctions compliance and risk management as key priorities. Among other topics, the paper discusses practical considerations and challenges related to leveraging blockchain analytics tools, structuring risk-based transaction monitoring procedures and addressing sanctions compliance obligations for digital asset transactions. The paper then addresses similar AML and sanctions control considerations from the perspective of traditional financial institutions that have dealings with digital asset firms or digital asset activities. For compliance teams and legal practitioners, this paper provides an actionable understanding of the AML and sanctions framework for digital assets and how to operationalise a compliance programme that appropriately addresses relevant risks and regulatory obligations. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/ business/.
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Author's Biography
Satish M. Kini is the Co-Chair of Debevoise’s National Security practice, the Chair of the Banking Group and a member of the Financial Institutions Group. He advises leading financial institutions on a broad range of US regulatory, compliance and transactional matters. Mr Kini represents banks, securities firms, insurers and asset managers in navigating complex regulatory frameworks, including those related to antimoney laundering, economic sanctions, data privacy and security, the Volcker Rule and affiliate transactions. He assists clients in developing robust compliance programmes and governance structures and regularly secures regulatory approvals for mergers, acquisitions and other transactions from US federal and state banking agencies. He also counsels clients on enforcement and examination matters before the federal banking agencies and the Office of Foreign Assets Control (OFAC) and provides guidance on cross-border regulatory issues, including sanctions and money laundering risks associated with international transactions and outsourcing arrangements. Mr Kini frequently advises financial institutions and industry trade associations on major regulatory reforms and engages with federal regulators and policymakers on behalf of clients and industry coalitions to shape and clarify key regulatory developments.
Aseel M. Rabie is a member of Debevoise & Plimpton LLP’s National Security practice and the Banking and Financial Institutions Groups. Ranked in Chambers USA (2025) and Chambers Global (2026), Ms Rabie focuses her practice on advising financial institutions, multinational corporations and other clients on a broad range of regulatory, supervisory and enforcement matters in the sanctions and anti-money laundering space. She also works closely with clients on compliance programmes and risk mitigation strategies and provides counsel on matters involving financial crimes in the context of transactions, fundraising, lending and investigations. Ms Rabie provides guidance on navigating complex US regulatory requirements and frameworks, including those implemented by the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN). Her practice also encompasses engagement with US federal regulators, including the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA), on policy, rulemaking and enforcement matters. Ms Rabie has extensive experience helping clients manage compliance and operational risks in international business contexts.
Jonathan R. Wong is a member of Debevoise & Plimpton LLP’s National Security practice and the Banking and Financial Institutions Groups. His work focuses on regulatory, transactional and enforcement matters, with particular emphasis on anti-money laundering (AML) and sanctions matters and the Outbound Investment Security Program (OISP) governing US investments in certain national security technologies and products in countries of concern. Mr Wong advises US and non-US banks and other financial institutions on AML and sanctions compliance obligations, assisting clients in developing and refining policies and procedures. He also counsels clients on supervisory matters, including examinations, formal and informal enforcement actions, governance and regulatory reporting. In addition, Mr Wong supports the firm’s private equity, M&A, finance and white collar & regulatory defence practices on transactional and enforcement matters involving AML, sanctions and OISP-related issues.
