Crypto Law Profile

FATF Recommendation 15 and Interpretive Note on Virtual Assets and VASPs

Global AML/CFT standard applying FATF measures to virtual assets and VASPs, covering risk assessments, licensing or registration, supervision, sanctions and Travel Rule information.

International In force Global standard Jun 21, 2019

At a glance

Status In force as a FATF global standard; Recommendations page says amended June 2026.
Jurisdiction International standard implemented through national AML/CFT laws and supervision.
Core scope Applies FATF AML/CFT measures to virtual assets and VASPs under R.15/INR.15.
Travel Rule Applies R.16 originator and beneficiary information expectations to VASP transfers.

Overview

FATF Recommendation 15 and its Interpretive Note to Recommendation 15 (R.15/INR.15) are the FATF global standards for applying anti-money laundering and counter-terrorist financing controls to virtual assets and virtual asset service providers (VASPs). FATF adopted the virtual-asset Interpretive Note on June 21, 2019, after amending Recommendation 15 in October 2018 to clarify how the FATF standards apply to virtual assets and VASPs. As of July 20, 2026, the Recommendation remains part of the FATF Recommendations, which FATF says were last updated in June 2026.

The standard is not a domestic statute and does not itself license any crypto business. Instead, it sets a benchmark that FATF members and FATF-style regional body jurisdictions are expected to implement through national legal, regulatory, supervisory and enforcement frameworks. FATF assesses implementation through mutual evaluations and targeted updates, including its 2026 report on virtual assets and VASPs.

Key Provisions of FATF Recommendation 15 for Virtual Assets

Recommendation 15 is titled “New technologies.” The core recommendation requires countries and financial institutions to identify and assess money laundering and terrorist financing risks from new products, business practices, delivery mechanisms and technologies. For virtual assets, it says countries should ensure VASPs are regulated for AML/CFT purposes, licensed or registered, and monitored for compliance with relevant FATF measures.

Risk-based approach

INR.15 applies the broader FATF risk-based approach to virtual asset activity. Countries should identify, assess and understand money laundering, terrorist financing and proliferation financing risks associated with virtual asset activities and VASPs, and should require VASPs to identify, assess and mitigate their own risks. This places risk assessment at the center of national implementation, rather than treating all virtual asset activity identically.

Licensing, registration and supervision

The Interpretive Note states that VASPs should be licensed or registered at least where they are created, or where a natural-person VASP has its place of business. Jurisdictions may also require licensing or registration where VASPs offer services to local customers or operate from the jurisdiction. FATF also calls for competent-authority supervision or monitoring, not supervision by a self-regulatory body, with powers to inspect, compel information and impose sanctions.

Preventive measures and Travel Rule information

INR.15 applies FATF preventive measures to VASPs, subject to specific qualifications. It sets a USD/EUR 1,000 threshold for occasional transactions requiring customer due diligence, and applies Recommendation 16 information-sharing obligations to virtual asset transfers. In practice, this is the FATF Travel Rule framework for VASPs: originating VASPs are expected to obtain and hold originator and beneficiary information, transmit it securely to beneficiary VASPs or financial institutions, and make it available to authorities on request.

Jurisdictional Impact and Implementation

The effect of R.15/INR.15 is global but indirect. Countries implement the standard differently depending on domestic legal systems, regulator structure and risk assessments. A jurisdiction may choose licensing, registration, prohibitions or other measures, but FATF expects measures that address AML/CFT and proliferation-financing risks, support supervisory oversight and enable enforcement against unlicensed or non-compliant VASPs.

FATF’s 2026 targeted update says jurisdictions have made progress since the 2025 update by conducting VA/VASP risk assessments, developing regulatory approaches, licensing or registering VASPs, implementing the Travel Rule, and advancing supervision and enforcement. FATF also reported remaining gaps in translating risk assessments into mitigation measures, operationalizing licensing or registration frameworks, identifying persons conducting VASP activity, and ensuring effective risk-based supervision and enforcement.

Status and Timeline

The key 2019 milestone was FATF’s public statement from Orlando, Florida, announcing the adoption and issuance of the Interpretive Note to Recommendation 15. The current FATF Recommendations page states that the Recommendations were adopted on February 16, 2012, regularly updated since, and last updated in June 2026. For CryptoSlate taxonomy purposes, this profile should be treated as an International global standard with an “In force” status, while noting that national legal obligations depend on each jurisdiction’s implementation.

Related internal reference points include the International jurisdiction archive and the AML/CFT, Licensing & Registration, Payments and Market Structure & Regulatory Perimeter topics.

Key provisions

Risk-based VA/VASP assessment

Countries should identify, assess and mitigate ML/TF/PF risks from virtual asset activities and VASPs; VASPs should assess and mitigate their own risks.

AML/CFT Jun 21, 2019 Source

VASP licensing or registration

VASPs should be licensed or registered at least where created or, for natural persons, where their place of business is located.

Licensing Jun 21, 2019 Source

Competent-authority supervision

VASPs should be supervised or monitored by a competent authority, not a self-regulatory body, with powers to inspect, compel information and sanction.

Supervision Jun 21, 2019 Source

Preventive measures and Travel Rule

FATF Recommendations 10-21 apply to VASPs, including CDD for specified occasional transactions and R.16 information for VA transfers.

Travel Rule Jun 21, 2019 Source

International cooperation

Countries should provide wide, rapid and constructive cooperation on ML, predicate offences and TF involving virtual assets, including supervisor exchanges.

Cooperation Jun 21, 2019 Source

Timeline

  1. FATF Recommendations adopted

    FATF adopted the 2012 Recommendations, later updated to include virtual assets.

    Enacted Source
  2. R.15 amended for virtual assets

    In October 2018, FATF revised R.15 and added VA/VASP glossary definitions.

    Enacted Source
  3. Interpretive Note issued

    FATF adopted and issued INR.15 on virtual assets and VASPs.

    Enacted Source
  4. INR.15 revised for PF risk

    June 2021 revision clarified proliferation-financing risk assessment and mitigation for VAs and VASPs.

    Enacted Source
  5. Recommendations last updated

    Current FATF Recommendations page states the standards were last updated in June 2026.

    Enacted Source
  6. Seventh targeted update

    FATF published its 2026 update on R.15 implementation, progress and remaining gaps.

    Enacted Source

Who it affects

Actors

Financial Action Task Force, National AML/CFT Supervisors, Virtual asset service providers

Asset classes

Virtual assets

Official sources

Editorial note

This profile treats FATF R.15/INR.15 as an operative global standard, not a self-executing domestic law. National duties depend on each jurisdiction’s implementation.