ACAMS Today, Jun-Aug 2023 | Page 62

Possible cryptocurrency impact to the fund
COMPLIANCE

Over 6,000 victims of 9 / 11 alone have received compensation through USVSST

Considering how the fund could be supported in the future , Steven Pelak , one of the initial architects of the proposal leading to the USVSST said , “ The principal means of financing the USVSST Fund is unlikely to change materially in the coming years . That said , one may anticipate that other nations , such as Russia , may be added to the roster of designated state sponsors of terrorism . If determined to be warranted by the Biden administration or Congress , the addition of Russia to the list of state sponsors of terrorism may materially increase the number of fines , penalties , and forfeitures available annually to finance the USVSST Fund . Finally , one may also anticipate that Congress may determine that victims of state sponsored terrorism should hold a greater voice at criminal sentencings involving defendants [ who ] willfully assist Iran and other state sponsors of terrorism . If so , one may reasonably expect that the [ U . S Department of Justice ( DOJ )] may more consistently and strongly pursue sanctions and other national security enforcement actions against those persons who assist the industries , finances , and economies of designated state sponsors of terrorism in violation of U . S . law .”

Possible cryptocurrency impact to the fund

AFC specialists have questioned how to regulate cryptocurrencies in recent years . These questions are no different for those keeping an eye on the USVSST Fund . What if state sponsors of terrorism begin to use virtual currencies with untraceable funds ? Will this change impact the future of the fund ?
Different states have different laws and these are still in flux given the novelty of virtual currency . 14 In 2020 , Congress explicitly stated that businesses that exchange virtual currencies are considered regulated entities . All regulated entities must register with the Financial Crimes Enforcement Network ( FinCEN ) and the Bank Secrecy Act ( BSA ), meaning they must advance and retain an AML compliance program . 15 Although there is little uniformity across the board , the hope is that these new laws will be
The remains of the World Trade Center Tower South ’ s steel shell in the days after the terrorist attack in New York City on September 11 , 2001 .
62 acamstoday . org