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Research Thread · Regulatory Landscape

Virtual Assets & the AML Regime

How FATF, Singapore, and the EU are trying to regulate what they can barely see

FATF R.15 MAS PSN02 MiCA · TFR Travel Rule Draft in progress ◉
I

The Structural Problem

Coming soon — why crypto breaks conventional AML logic. Pseudonymity at the address level, instant cross-border transfer with no correspondent banking layer, programmable obfuscation, and a global ledger that is simultaneously transparent and hard to attribute.

II

FATF and the Attempt at Global Standard-Setting

Coming soon — Recommendation 15, the Travel Rule, and the 2023 finding that 75% of jurisdictions remain only partially or non-compliant. The gap between standard-setting and real-world implementation is itself the story.

III

Singapore's Approach

Coming soon — MAS PSN02, the Digital Payment Token licensing regime under the Payment Services Act, and how the Travel Rule lands in practice at the S$1,500 threshold.

IV

The EU's Bet

Coming soon — MiCA, the Transfer of Funds Regulation, and the case for a unified 27-country passport with no de minimis Travel Rule threshold. How the 18-month grandfathering period creates an interim patchwork.

V

Comparing the Two

Coming soon — different jurisdictions, different bets. Enforcement capacity, supervisory philosophy, and the question of which model travels well to mid-size emerging market regulators.

VI

The Typologies

Coming soon — what regulation is actually chasing: mixer and tumbler usage, chain-hopping, DeFi as a layering vehicle, and exploitation of P2P networks. Ties into the on-chain case study.

VII

Where This Goes

Coming soon — open questions, honest unknowns. A student's view, not a policy prescription. What I now know I don't know.

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This piece is being written in stages as the research develops. Sections will be published as they are ready. Last updated: May 2026.

 

Roo’s Observatory ✦ · soft mind, sharp thinking · 2026