Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
BIS Proposes Scoring Model for Crypto AML
AML | Aug 21, 2025
Image: Freepik/Sentavio
BIS Introduces AML Compliance Score Model for Crypto
On August 13 2025, the Bank for International Settlements (BIS) published a new bulletin proposing a fresh approach to anti money laundering (AML) compliance for cryptoassets. The paper suggests using the public record of blockchain transactions to generate AML compliance scores that could be applied when crypto is exchanged for fiat at off ramps.
Key Takeaways
- Traditional AML rules that rely on intermediaries are not effective for permissionless blockchains
- Blockchain transaction history can be used to assign AML compliance scores
- These scores could be checked at off ramps to prevent illicit funds from entering banks
- A scoring model could encourage a culture of duty of care across the crypto ecosystem
Why Traditional AML Approaches Fall Short for Crypto
Most AML rules today rely on regulated intermediaries like banks to perform customer checks, however that approach doesn't work well for permissionless blockchains, where records are maintained by decentralized validators instead of a single entity. Once crypto moves from an exchange to an unhosted wallet, conventional checks lose their reach. This gap is important as stablecoins have overtaken bitcoin as the main vehicle for illicit crypto transactions, accounting for an estimated 63% of criminal activity in 2024 according to both the Chainalysis 2025 crypto crime report.
How AML Compliance Scores Could Work
The BIS paper suggests using blockchain’s public history to assign compliance scores to cryptoassets. A higher score would indicate clean funds tied to verified wallets, while a lower score would suggest links to illicit addresses. Authorities could set thresholds for AML triggers, with banks, exchanges, or stablecoin issuers applying the rules at off ramps.
See: UK FCA Plans Full Crypto Licensing Regime by 2026
This scoring model could range from strict to permissive. A strict version would only allow coins from verified 'okay listed wallets'. A permissive version would block only those funds that have touched 'not okay listed addresses'. Intermediate models could combine multiple criteria, such as recent wallet history, periods of holding on allow listed addresses, or interaction with suspicious protocols.
This approach aligns with the Financial Action Task Force’s travel rule guidance for virtual assets and VASPs and complements Canada's domestic efforts by FINTRAC to strengthen monitoring of crypto transactions. By integrating compliance scores at conversion points, Canadian exchanges and banks could reduce risk while supporting innovation.
There are also implications for monetary policy and sovereignty. The BIS notes that widespread cross border use of stablecoins can undermine local regulations. Differentiating coins based on where they come from could help Canada maintain stronger controls over its financial system. In practice, clean stablecoins could trade at a premium over those with a questionable history, creating incentives for compliance.
Building a Duty of Care Culture
If compliance scores were the standard, all ecosystem participants from retail wallet holders to major exchanges would need to exercise a duty of care. That alone could spur growth of third party compliance services as the market moves to support cleaner transactions.
See: OSC Crypto Trading Platform Compliance Review Findings
Compliance scoring would increase new technical requirements for fintechs while opening the door for services and tools that help users assess risk. As Canadian and global regulators weigh next steps in crypto regulation, the BIS compliance scoring model offers an approach that combines blockchain transparency with regulatory safeguards. NCFA members can stay ahead of these changes by subscribing to the weekly NCFA newsletter for updates on compliance, policy, and fintech innovation.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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