PART III – Crypto-assets, Anti-Money Laundering and Emerging Risks for the Board of Directors

by Lorenzo Savastano – Officer of the Guardia di Finanza – Major[1]

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This contribution represents the second in-depth analysis of the series dedicated to certifications AMLACERT® and CAMS of ACAMS and their strategic impact on AML/CFT compliance. After analyzing the importance of continuing education in standards with Dr. Alfonsina Leo, Financial Action Task Force (FATF)/FATF, the intervention of Major. Lorenzo Savastano, an officer of the Guardia di Finanza, addresses an emerging risk front: crypto-assets. The article explains why these technologies are now central to preventing money laundering and how certified expertise can protect organizations and boards of directors from the associated risks.
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Cryptocurrency and Anti-Money Laundering: Why It's Important to Talk About It

Let's start with the data.

Chainalysis's latest Crypto Crime Report highlighted that in 2024, the value of illicit financial transactions imprinted on the blockchain will reach nearly $40 billion, or 0,14% of the total value of financial flows transacted on DLT protocols.

Looking at the same data from a different perspective, we discover that the overall value of on-chain transactions in the last year was approximately $28.571 billion ($28,57 trillion). To understand the scale of the phenomenon, consider that Visa – the world's leading digital payments company – handled transactions worth $14 trillion in 2023[2]: just half of those circulating on decentralized finance protocols the following year (sic!).

Moving then the attention from financial flows to assets under management, based on the estimates of Defillama.com, the total value of digital assets deposited within the algorithmic folds of smart contracts (so-called Total Value Locked – TVL) is currently equal to 140,8 billion dollars[3]: approximately 0,13% of the value of global finance, which reached the value of 109 trillion dollars in 2023[4].

If the percentage of on-chain financial wealth seems to be limited, consider that in 2007 the value of US sub-prime mortgages, shortly before the disastrous and epochal bursting of the speculative bubble, was equal to 1,3 trillion dollars[5], equivalent to just under 0,67% of the total value of world finance (which, at the time, had reached the monstrous peak of 194 trillion dollars[6]).

The consideration that must be made is therefore clear: crypto-assets are no longer just a promise of libertarian renewal in global finance, but also a physiognomic feature of the contemporary economy, which has reshaped the face and identity of markets, industry players and (it goes without saying) criminal groups.

This is why global standard-setters and regional legislative bodies have long attempted to regulate the phenomenon – with different approaches, strategies, and, above all, outcomes – as demonstrated, among others, by the mirror-image European Market in Crypto-Asset (MiCa) and Transfer of Funds Regulations, as well as the symbiotic GENIUS and CLARITY Acts on the other side of the Atlantic Ocean.

In this context, Boards of Directors (BODs) can no longer consider crypto-assets a "niche" or marginal area. Instead, these technologies represent an emerging front of anti-money laundering risk and, consequently, a sector requiring up-to-date, specific, and—most importantly—certified expertise.

Cryptocurrency and Anti-Money Laundering: Why Education Is Important

Once again, let's start with the numbers. According to the latest report from the Bank of Italy's Financial Intelligence Unit, the total value of suspicious financial transactions reported by obliged entities in 2024 is over 100,5 billion euros. Considering that STRs related to the use of digital assets represent 3,8% of the total[7], it is easy to estimate that the value of transactions in crypto-assets potentially at risk of money laundering or terrorist financing in Italy is over 3,8 billion euros.

A veritable "digital" river of money, which risks overflowing into the legal economy if not adequately contained by specific due diligence measures, continuous monitoring, data retention, and international cooperation, in line with the FATF Recommendations, which, in 2019, introduced a specific global standard for the regulation of Virtual Asset Service Providers (VASPs).

The concrete application of the aforementioned principles requires preliminary, pre-emptive, and thorough technical knowledge of the ways in which digital assets are currently used, including for illicit purposes.

In this context, the use of certified professionals, such as holders of AMLACERT or CAMS (Certified Anti-Money Laundering Specialist) certifications, represents a strategic choice for every Board of Directors in risk management.

These certifications include training modules that specifically and comprehensively address the risks associated with crypto-assets, updated in accordance with the latest international, European, and national guidelines.

The inclusion of professionals trained in this field allows for:

• implement monitoring systems consistent with technological developments;
• update the company's risk appetite to include digital assets;
• make informed assessments when reporting suspicious transactions.

Even in the context of Legislative Decree 231/2001, the presence of specialists certified on ML-TF risks associated with crypto-assets can in fact allow the institution to:

• update Model 231 by inserting specific references to emerging risks;
• prepare dedicated policies for the management of crypto-assets (VASP customer onboarding, wallet management, suspicious activity reporting);
• implement incident response procedures related to illicit cryptocurrency operations;
• define audit and control protocols consistent with international standards (FATF, EBA, ESMA).

The presence of certified professionals can therefore allow the company to concretely demonstrate that it has acted diligently, designing an organizational risk prevention model also based on the solid training of the resources involved.

Cryptocurrency and Anti-Money Laundering: Why Certification is Important

In an increasingly complex regulatory and operational context, where crypto-assets are establishing themselves as a structural component of financial markets, it is no longer enough to be informed: you need to be prepared with adequate tools, integrated methods and certified skills. For the Boards of Directors, this means focusing on internationally recognized training courses, which ensure comprehensive preparation also on emerging risks such as DeFi, NFTs and Un-hosted wallets. This choice allows us to demonstrate the highest level of diligence required by FATF standards and to strengthen the organization's protection both operationally and in terms of the liability of its top management.

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[1] private intervention that does not reflect the orientation of the Administration to which it belongs.

[2] Source: R. KHALAF, American love of credit cards will blunt instant payment appeal, published on the Financial Times website, 15 October 2024.

[3] Data updated to July 2025.

[4] Source: D. NEUFELD, The $109 Trillion Global Stock Market in One Chart, published on the Visual Capitalist website, September 27, 2023.

[5] Source: NBC news, March 13, 2007.

[6] Source: McKinsey Global Institute.

[7] See Bank of Italy Newsletter no. 4/2025 of June 2025. Specifically, these are 6.255 SOS relating to digital assets, out of a total of 145.401 reports.

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