Abstrak

The Digital Asset Markets has new opportunities, but these come with unique challenges for the anti-money laundering (AML) framework. While there has been progress on blockchain analytics and regulatory directions, country-level evidence on the practitioner experience of, and responses to, virtual-asset risks remains scant. This paper attempts to bridge this gap through the use of a qualitative, survey-based design, to document challenges related to AML/CFT in Uzbekistan’s emerging digital-asset ecosystem. We carried out semi-structured online semi-structured survey with 25–40 purposively sampled relevant stakeholders: compliance officers at VASPs and banks, FIU analysts, regulators, legal experts and academics, and coded and analyzed responses thematically. The results indicate a risk perception of anonymity-enhancing technologies (mixers, privacy coins), peer-to-peer trading, cross-chain bridges, and DeFi primitives as the main AML risks; and a limit of blockchain traceability where regulatory implementation parameter, supervisory capacity and international information exchange parameter are weak. Travel Rule compliance and cross-border data exchange were always awarded low scores, whilst KYC/CDD and blockchain analytics were deemed only moderately effective. The Uzbekistan-specific results show a moderately strong legal framework and partial coordination with the FATF, along with some institutional weaknesses to conduct investigations and enforcement. The paper concludes that a risk-based, comprehensive response is required for effective AML in digital-asset markets: improve FIU and developmental supervisory technical capabilities, ensure interoperable Travel-Rule solutions are mandated and rolled out, commit to cross-border cooperation and calibrate regulation to foster innovation while avoiding arbitrage. These insights, informed by practitioners, provide an empirical basis for policy reform and for future longitudinal research.

Kata Kunci
digital assets anti-money laundering Uzbekistan VASPs Travel Rule DeFi blockchain analytics
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