2026-11-12

Reporting suspicious crypto activity: Bridging supervisory expectations and operational realities

This report summarises discussions at “Crypto STRs in practice: bridging supervisory expectations and operational realities”, a breakout session organised by the Wolfsberg Group and the Basel Institute on Governance at the 2026 Global Conference on Criminal Finances and Cryptoassets. This workshop brought together supervisors, FIUs, financial institutions and cryptoasset service providers to discuss the practical challenges of crypto-related suspicious transaction and activity reporting (STR/SAR) and how its effectiveness can be improved. The discussions highlighted eight recurring considerations that participants regarded as relevant to improving the effectiveness of suspicious crypto activity reporting. Their application remains subject to the applicable legal and regulatory framework and to reporting entities’ risk-based assessments.

  1. Judge STRs/SARs by their intelligence value, not their volume. A good report is one that competent authorities can act on. Large volumes of reports that contain limited contextual or intelligence value may place pressure on both reporting entities and authorities and make prioritisation more difficult. Improving report quality can help authorities identify and analyse the most relevant information, while recognising that reports of limited apparent value in isolation may become significant when combined with other information.
  2. Alerts and red flags are only a starting point. Red flags, alerts and risk scores are a starting point for analysis, not a reason to file. Reporting entities should use professional judgement and report when the information supports a genuine suspicion. Reporting simply to avoid criticism, or because questions remain open, adds little value.
  3. Explain the reasoning behind the suspicion. The most valuable reports give a clear narrative: why the activity is suspicious, what was reviewed, what steps were taken and how the evidence led to the conclusion. Relevant context matters more than including every piece of available information.
  4. Get the data right and make it machine-readable. Accurate identifiers, complete transaction data and structured formats such as XML allow FIUs to link reports, including across borders. These formats should cover all relevant persons, entities, transactions and accounts, including cryptoasset accounts. A report of limited value on its own can become significant when combined with information held elsewhere.
  5. Use blockchain analytics alongside other sources. There was broad agreement that these tools should support, rather than replace, human analysis and decision-making. The tools are valuable, but attribution can be incomplete, data quality varies and providers’ methods differ. The strongest reports combine analytics with customer due diligence, transaction monitoring, behavioural indicators and open-source research. Where permitted by the applicable reporting framework, and where useful and proportionate, participants considered that relevant extracts or information explaining the analytics output may help the receiving FIU understand the basis of the assessment.
  6. Make analytics more transparent and pursue common standards. Participants favoured developing standards on governance, taxonomy and explainability of blockchain analytics tools. This would improve comparability without stifling innovation.
  7. Join up the picture through cooperation. Banks see fiat flows and customer profiles, CASPs see platform and on-chain activity, and authorities see across reports. Public-private and private-to-private dialogue, especially between banks and CASPs, helps close these gaps within legal limits. Public authorities have a role in building trust and facilitating that dialogue.
  8. Feedback improves reporting over time. Case-by-case feedback is hard for stretched FIUs. Other channels can still help reporting entities learn what is useful and reduce defensive reporting, including typology and negative typology publications, thematic guidance, periodic quality feedback and structured dialogue.

A question mark remains around how far should reporting entities trace historical cryptoasset activity. Participants agreed that a proportionate approach is needed, but there was no common position on what that means in practice. A typical case is a bank receiving funds from a MiCA-licensed CASP where the source of wealth is understood and there are no red flags. A licence is relevant but not decisive. Related questions concern how much information institutions can reasonably request from customers, some of whom are reluctant to disclose wallet details for privacy and security reasons, and whether that reluctance should itself be treated as a risk indicator.

Developing that guidance – and continuing to work through the challenges and good practices indicated above to enhance their application in practice – is a joint task for public authorities and reporting entities. Initiatives and networks such as the Global Conference on Criminal Finances and Cryptoassets, the Wolfsberg Group and the Europol Financial Intelligence Public-Private Partnership (EFIPPP) are powerful forums to take that work forward.

You can find the full report here.

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