Crypto Law Profile

Israel AML Order for Financial-Asset Service Providers

Israel’s AML/CFT order applies CDD, reporting, monitoring, screening and recordkeeping duties to credit and financial-asset service providers, including virtual-currency activity.

Israel Effective Regulation Nov 14, 2021

At a glance

Status In force; main 2021 amendment generally effective Nov. 14, 2021.
Covered providers Covers licensed credit providers and financial-asset service providers, including virtual-currency activity.
Core duties Imposes identification, KYC, reporting, monitoring, screening and recordkeeping duties.
Travel Rule caveat Section 7A(b)(2) needs editor verification for its separate commencement date.

Overview

Israel’s Prohibition on Money Laundering Order for Providers of Service in Financial Assets and Credit Service Providers is a binding AML/CFT regulation for supervised non-bank financial service activity. The original 2018 order applied to credit-service providers, and the 2021 amendment expanded the order to providers of service in a financial asset, including virtual-currency service activity. The amended order is treated here as in force, with the general 2021 commencement date of Nov. 14, 2021.

Scope of the Israel financial-asset AML order

The order sits under Israel’s Prohibition on Money Laundering framework and the regulated financial services licensing regime. It uses the term “service provider” to cover credit providers and providers of service in a financial asset that are required to hold a license under the Regulated Financial Services Law. The 2021 amendment also added a definition of “virtual currency,” generally covering a digital unit or representation of value that can be traded or transferred digitally and used for payment or investment.

For crypto-market readers, the order is most relevant because it places virtual-currency service activity within the same operational AML framework used for other covered money-service activity. It does not create a standalone crypto statute. Instead, it updates Israel’s AML order so that covered financial-asset providers, including virtual-asset activity, are subject to identification, risk review, reporting, list-screening and recordkeeping duties.

Key AML/CFT obligations

The order requires covered providers to adopt customer-identification and know-your-customer procedures, register identifying details, and assess the risk profile of service recipients. The official English consolidation describes ongoing monitoring, enhanced review for higher-risk cases, and treatment of politically exposed persons and service recipients linked to listed countries or territories.

Reporting obligations include ordinary threshold-based reports and reports of unusual activity, including attempted transactions. For virtual-currency activity, reportable details can include the type and amount of virtual currency, wallet addresses, blockchain transaction identifiers, exchange-rate information, and certain device or network details when service is provided online or through an application.

The order also requires screening against terrorism and proliferation-financing lists, maintenance of digital databases, and retention of transaction and identification records for at least five years. Records for virtual-currency transfers can include originator and beneficiary information, wallet addresses, IP data, IMEI data and other transaction details.

Virtual-currency transfer information

A major crypto-specific feature is section 7A, which addresses electronic transfers and virtual-currency transfers. The text requires covered transfer records to include identifying details for the originator and beneficiary and, for virtual currency, wallet-address information and transfer-related details. One provision, section 7A(b)(2), has a separate commencement mechanism: the 2021 amendment states that it begins on a date set by the Commissioner, rather than automatically on the general eight-month commencement date.

That caveat matters for editorial status. Official Capital Market Authority reporting later described a public call for input on implementation of the Travel Rule for electronic transfers and virtual currencies, including technological readiness, privacy and information-transmission issues. Editors should verify the current operative status of section 7A(b)(2) before characterizing that particular transmission duty as fully in effect.

Status and timeline

The 2018 order was published in Israel’s official gazette on Mar. 14, 2018, with original commencement on Mar. 15, 2018. The amendment extending the order to financial-asset service providers was published on Mar. 14, 2021 and signed by the Minister of Finance on Feb. 28, 2021. The amendment provides for commencement eight months after publication, making the general effective date Nov. 14, 2021.

For CryptoSlate taxonomy purposes, this profile maps the measure to “Regulation” rather than “Decree” or “Act,” because the controlled taxonomy does not contain an “Order” type and the instrument functions as a binding AML/CFT regulatory order. The current status is “In force,” subject to the section 7A(b)(2) implementation caveat noted above.

Key provisions

Scope and virtual-currency definitions

Extends the 2018 credit-provider AML order to providers of service in a financial asset and defines virtual currency.

AML/CFT Nov 14, 2021 Source

Customer due diligence

Requires identification, KYC procedures, risk profiling and registration of service-recipient identity details.

AML/CFT Nov 14, 2021 Source

Threshold and unusual-activity reports

Requires threshold-based and unusual-activity reports, including attempted transactions and specific virtual-currency data.

Reporting Nov 14, 2021 Source

Virtual-currency transfer information

Section 7A addresses virtual-currency transfer data; subsection 7A(b)(2) has a separate commencement mechanism.

Transfers Source

Recordkeeping and digital databases

Requires digital databases and retention of identifying and transaction records for at least five years.

Recordkeeping Nov 14, 2021 Source

List screening and higher-risk monitoring

Requires screening against terrorism and proliferation-financing lists and ongoing monitoring of higher-risk relationships.

AML/CFT Nov 14, 2021 Source

Timeline

  1. Original order published

    Official Gazette published the 2018 order for credit-service providers.

    Enacted Source
  2. Original order commenced

    Original order commenced for credit-provider AML obligations, subject to transition rules.

    In force Source
  3. 2021 amendment signed

    Finance Minister signed the amendment extending the order to financial-asset service providers.

    Enacted Source
  4. 2021 amendment published

    Official Gazette published the title and scope changes for financial-asset providers.

    Enacted Source
  5. Main amendment in force

    General commencement occurred eight months after publication.

    In force Source
  6. Travel Rule input process reported

    In Sept. 2023, authority sought input on Travel Rule implementation for virtual-currency transfers.

    Under consultation Source

Who it affects

Actors

Capital Market, Insurance and Savings Authority, Israel Money Laundering and Terror Financing Prohibition Authority, Ministry of Finance, Ministry of Justice

Asset classes

Virtual currency

Official sources

Editorial note

Mapped to the controlled type term “Regulation” because the available taxonomy does not include “Order.” Status is “In force” for the amended order generally, with an editor-review caveat for section 7A(b)(2) commencement.