2023/06/12: From “know the client” to “know tha avatar”. Anti-money Laundering obligations in the metaverse.

The new virtual world of the metaverse raises many legal questions. While the metaverse offers several positive applications and opportunities, it may also have risks, including new potential money laundering opportunities. The question therefore arises to what extent new measures should not be taken to ensure the identification of virtual customers and the monitoring of virtual transactions.

The metaverse, new (criminal) opportunities

Financial magazine Forbes carried the story in March 2023 that the metaverse platform Roblox was involved in criminal proceedings in federal court in San Francisco after suspicious transactions were identified on the Roblox platforms. According to the indictment, more than 300 Roblox users allegedly laundered money by using in-game currency to purchase fake goods. This allowed them to forward money to each other which amounted to money laundering. The case ended with an out-of-court settlement, without Roblox admitting guilt. The Roblox case is a great example of how criminals are trying to use the metaverse to launder criminal money.

And that the metaverse is attractive for criminal activity is not surprising. The ability to conduct business anonymously via avatars, crypto-currencies and NFTs in virtual economies that are little regulated make the metaverse an ideal playground for criminals, particularly for developing money laundering schemes. It is clear that the rise of the metaverse and web3.0 can facilitate money laundering.

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