CFTC and Tokenized Assets: 2025 Guidance
In 2025 — specifically following the signing of the GENIUS Act (a law on stable cryptocurrency signed in July 2025) in the USA — and the tightening of cryptocurrency market regulations, the rules of the game for digital asset users have changed. In addition, international standards such as MiCA in the EU have also toughened the approach to AML screening, KYC procedures, and transaction monitoring. This has created new risks, including the likelihood of funds being blocked, especially if they are linked to so-called "dirty crypto."
In this article, we will break down the key steps to help you minimize the risks of blocking and protect your assets.
Risks of Blocking Funds: Why It Matters
The GENIUS Act requires issuers and platforms to have:
- Effective Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) programs and transaction screening procedures.
- Mechanisms for compliance with sanctions requirements and, if necessary, the blocking or freezing of funds associated with sanctions labels or suspicious operations.
- Compliance with KYC procedures and Bank Secrecy Act (BSA) requirements for entities subject to the law.
These measures increase the probability of your account being blocked if you accidentally receive funds from an address appearing on sanctions lists. Furthermore, non-custodial wallets may face increased monitoring from services and platforms required to comply with the GENIUS Act and other jurisdictions; however, the law itself directly regulates primarily stablecoin issuers and participants subject to US jurisdiction, rather than all non-custodial wallets universally.
How to Protect Yourself: A Practical Guide
1. Address Verification Before Transfer
Before every transaction, be sure to check the recipient's address using wallet screening tools. This will allow you to identify links to "dirty crypto," sanctions labels, or suspicious activities.
Recommended services for verification:
- Chainalysis KYT
- Elliptic
- Crystal Blockchain
Using such tools reduces the risk of your funds being blocked due to them entering a suspicious chain.
2. Use Only Reliable Platforms
Choose platforms that:
- Publicly publish audits or attestations of reserves (for example, stablecoin issuers like Circle's USDC regularly publish reserve reports).
- Comply with GENIUS Act and MiCA requirements, as well as other applicable regulatory standards.
- Have a strict policy against "dirty crypto" and transparent compliance procedures.
Avoid platforms without a transparent KYC policy, as they may be targets of increased regulatory scrutiny.
3. Diversify Asset Storage
To minimize the risk of your entire portfolio being blocked:
- Store funds in multiple wallets, including non-custodial ones.
- Use multi-signatures (multisig) for large amounts.
- Keep a portion of your assets in fiat currency or other asset classes.
4. Monitor Updates to Sanctions Lists
Sanctions lists are updated regularly, and it is important to stay informed about these changes. You can subscribe to notifications from authorities such as OFAC or use API integrations for automated monitoring.
5. Increase Awareness of AML and KYC
AML and KYC are not just formalities; they are tools that help prevent blockages and strengthen your position before regulators. If you operate as a business, invest in the automation of these processes.
Conclusion
The regulation introduced by the GENIUS Act creates both challenges and opportunities for stablecoin users. To avoid having your funds blocked:
- Verify addresses before transferring.
- Work only with platforms that comply with the law.
- Diversify your asset storage.
Following these recommendations will allow you to minimize risks and maintain control over your funds. A responsible approach today is the guarantee of your financial security tomorrow.
Additional materials: Tokenized Assets and Their Risks.