Does an AML Check Consider Transaction History and the Origin of Crypto?

Why Transaction History Matters

A classic stage of money laundering is layering: moving funds repeatedly to disguise their source. In crypto, this often looks like:

  • rapidly splitting funds across many wallets;
  • moving funds between blockchains (e.g. USDT from one network to another);
  • converting one asset into another;
  • using mixers.

This is why transaction history is an integral part of wallet risk assessment.

USDT Across Several Wallets: Is It a Violation?

Not by itself. People move crypto between wallets for legitimate reasons: from an exchange to a personal wallet, between exchanges, or for security. Passing through several wallets is not automatically suspicious.

What matters is context: where the funds came from, why they moved, and whether there is any link to high-risk sources such as stolen coins, dark markets or sanctioned wallets.

What Is a Crypto Mixer and Why Does It Raise Flags?

A mixer (or tumbler) is a service that pools crypto from different users and redistributes it to new addresses, making the source of funds hard to trace. While some users turn to mixers for privacy, the FATF and supervisors treat them as high-risk tools because they are frequently used to conceal illicit proceeds.

How Blockchain Analytics Works

Blockchain analytics tools trace a wallet’s chain of transactions and determine whether the funds were linked to known risky addresses, directly or through several intermediary wallets. The transaction or wallet is then assigned a risk score.

Enhanced Due Diligence: What Happens When Mixer Exposure Is Found

If the analysis shows a link to a mixer, the transaction is subject to enhanced due diligence (EDD). This may include:

  • asking the customer for an explanation and documents confirming the source of funds;
  • temporarily holding the transaction until the review is complete;
  • where necessary, reporting suspicious activity to the Financial Monitoring Service.

The aim is not to penalise the customer automatically, but to assess the risk objectively.

Frequently Asked Questions

Does AML check where crypto comes from?
Yes. Blockchain analytics are used to review a wallet’s transaction history and any links to high-risk sources.

If my USDT passed through several wallets, will it be blocked?
Not automatically. Moving through several wallets is not a violation in itself; the context and any links to risky sources are what get assessed.

Why are mixers considered high-risk?
Because they deliberately obscure the source of funds, which is often used to hide illicit proceeds.

LC HUB: AML/CFT Consulting and Training

LC HUB (Legal & Compliance Hub) helps VASPs and fintech companies with:

  • transaction monitoring and wallet risk assessment procedures;
  • enhanced due diligence (EDD) processes;
  • AML/CFT frameworks and NBG compliance;
  • certified AML training, including a VASP-focused masterclass.

📞 Contact us: +995 551 51 93 39