Peter Van Valkenburgh: Coin Center – The Sanction on Tornado Cash
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The Risk Based Approach to Anti Money Laundering and Counter Financing of Terrorism
We have what is called, euphemistically, a risk based approach to anti money laundering and counter financing of terrorism policy. So seeing that i, for instance, am not an american, would they also close my accounts? I mean, is the transitive band orasily, if they interact with me, are then American banks disallowed to interact with my german banks? This gets into something that is also fundamental about the way we've done financial surveillance and control in the last half century. There's no clear standard and therefore the standard that that it becomes the default rule is just extreme risk ofversion because the penalties are so severe. Now, there's no black letter rule that
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