Are Nonfungible Tokens Subject to US Anti-Money Laundering Requirements?

Revue Trimestrielle de Droit Financier

Eytan J. Fisch Margot Sève

Skadden attorneys discuss whether nonfungible tokens (NFTs) are or may become subject to U.S. anti-money laundering regulations. Although the Department of the Treasury’s Financial Crimes Enforcement Network has not yet answered this question, recent developments and concerns of U.S. lawmakers and regulators regarding the financial crime risks associated with virtual assets make regulatory scrutiny of NFTs likely.