Anti Money Laundering and Counter Terrorism Financing


I’ve been searching high and low for the answer to this but I’m really confused about how Coil handles AML and CT financing.

I found this article that references a number of companies (Elliptic) who look at transactions, decide if they’re suspicious and then report them to the authorities.

In Coils terms there is nothing on AML.

I appreciate that their bank Stronghold does identity checks but is this enough?

I’m really interested in this topic since I see AML and CTF being a show stopper for mass adoption so if anyone can shed any light I’m interested!



Hey Matt,

This came up on the last ILP community call.
The thread may be of interest: Community Call - September 18th, 2019
(See especially Stefan’s comment on roles of participants)

Stronghold is not Coil’s bank. Stronghold is a digital wallet that creators can use to accept payments from Coil. Coil pays creators for their content using ILP and if those creators are using a Stronghold wallet then Coil settles with Stronghold for all the payments made to their users.

Interledger is a messaging protocol, similar to the protocols used on card networks for payments between PSPs and banks. Once payments have been sent via ILP they still need to be settled. (Each participant in a payment settles with their direct peer.)

As you can imagine this means that anyone one the network that wants to ensure they are complying with regulations must make sure they know what role they are playing (payer, payee, money transmitter) and abide by the regulations that govern that role.

If you peer with someone (accepting and or sending ILP packets from/to them) then you should be confident that relationship doesn’t change the nature of your role on the network.

Thanks Adrian, I’ll take a look!