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AML Program Design for Crypto

AML/KYC Tier 1

How to design and implement an Anti-Money Laundering program for cryptocurrency businesses, covering risk assessment, policies, procedures, training, and independent testing.

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Key Facts

  • **Law 14/2017 of 22 June on the prevention and fight against money laundering and the financing of terrorism:** This is Andorra's principal AML/CFT law, establishing the general obligations for all obliged entities. It has been subsequently amended to incorporate international recommendations. (AD)
  • **Law 9/2023 of 23 March on digital assets:** This specific law regulates virtual assets and their service providers, bringing VASPs under the scope of Law 14/2017 and defining the specific licensing and operational requirements for these entities. This law formally identifies VASPs as obliged entities for AML/CFT purposes. (AD)
  • Exchange between virtual assets and fiat currencies. (AD)
  • Exchange between one or more forms of virtual assets. (AD)
  • Custody and/or administration of virtual assets or instruments enabling control over virtual assets. (AD)
  • Participation in and provision of financial services related to an issuer's offer and/or sale of a virtual asset. (AD)
  • **Identification and Verification:** (AD)
  • Natural persons in Andorra must have their identity verified using reliable, independent source documents, data, or information (e.g., official ID cards, passports), and Andorra now permits digital and remote identity verification methods such as document scanning and biometric liveness checks under its UIFAND-compliant AML framework. (AD)
  • Identification number (e.g., passport number, national ID number) (AD)
  • **Legal Entities:** Obtain and verify the client's legal existence and structure, including: (AD)
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Last updated: 2026-04-29. View all topics