ComplyFirst reports reflect an independent analysis by ComplyFirst and is intended as a tool to help law enforcement, regulators and industry participants understand and evaluate information that may be relevant to AML compliance. The report does not reflect a legal conclusion and is no indication of qualitative value of an asset or suitability for investment or any other purpose and is solely for use by the ComplyFirst and not for reliance by any other party.
ComplyFirst’s analytical framework is based on relevant federal law, including FinCEN Guidance issued on May 9, 2019 (FIN-2019-G001). Neither the report nor our framework constitute an exhaustive treatment of the legal and regulatory issues relevant to conducting an analysis of AML compliance and ComplyFirst does not analyze other laws or regulations which may apply. The analysis concerning AML compliance may evolve over time as the nature of digital assets, applicable precedent and FinCEN statements and interpretations change and evolve. ComplyFirst’s framework has not been endorsed by FinCEN or any other government authority.
Any and all ComplyFirst reports are based on a limited review of factual information publicly available or otherwise made available to ComplyFirst. Not all potentially relevant factual information has necessarily been reviewed and no independent investigation or analysis, apart from ComplyFirst’s own efforts, has been taken to confirm information on which this analysis is based. We do not assume any responsibility for the completeness of the information upon which our analysis and determination is based. It is possible that if additional facts where known or assumed or understood facts prove to be incorrect, the analysis would be materially different.
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