Find your way around the Perimeter
The concepts that organise this territory, then the terms you will meet crossing it — money rails, sanctions, AML, crypto, EU and Swiss rules, and the geopolitics that connects them.
I The concepts — how to think about this territory
The Three Perimeters
Every cross-border payment crosses three boundaries at once: the sanctions perimeter states draw around adversaries, the compliance perimeter regulators draw around firms, and the geopolitical boundary that finance crosses faster than diplomacy. All three leak — and most enforcement stories are really stories about which perimeter leaked, where.
Why it matters: This is the frame the whole publication runs on.
The Risk-Based Approach
The cornerstone of FATF-era compliance: instead of applying identical checks to everyone, firms must identify, assess and mitigate their specific money-laundering and terrorist-financing risks, spending the most effort where risk is highest. In practice it converts compliance from a checklist into a judgment exercise — which is both its strength and the source of most supervisory disputes.
Why it matters: Almost every AML obligation you will ever read is an application of this principle.
Placement — Layering — Integration
The classic three-stage model of money laundering: dirty money enters the financial system (placement), is moved through transactions designed to obscure its origin (layering), and re-emerges as apparently legitimate wealth (integration). Crypto did not change the model; it changed the speed and geometry of the layering stage.
Why it matters: Typologies, monitoring rules and most enforcement narratives map onto these three stages.
Pseudonymity Is Not Anonymity
Public blockchains record every transaction forever under pseudonymous addresses. The ledger hides names, not behaviour: once any address is linked to a real-world identity — an exchange account, a delivery address, an off-chain leak — the entire transaction history around it becomes legible, retroactively and permanently.
Why it matters: It explains both why criminals still use crypto and why so many of them get caught.
The Off-Chain Gap
On-chain data shows where value moved; it cannot show who wanted it moved, or why. Sanctions exposure, dark-web activity, corporate structures and human networks live off-chain. Monitoring that reads only the ledger systematically misses the signals that connect transactions to real-world risk.
Why it matters: The structural blind spot behind a large share of crypto-compliance failures.
The Attribution Problem
Connecting a blockchain address to a real-world actor is inference, not lookup: it rests on clustering heuristics, exchange records, open-source intelligence and sometimes seized data. Attribution confidence varies enormously, and the difference between "linked to" and "controlled by" decides whether evidence survives in court.
Why it matters: Every investigation, sanction designation and analytics product stands or falls on it.
Weaponized Interdependence
Farrell and Newman’s term for how states that sit on network hubs — dollar clearing, SWIFT messaging, chip supply chains — can turn those chokepoints into instruments of coercion, monitoring flows (the panopticon effect) or cutting adversaries off (the chokepoint effect). Financial infrastructure is not neutral plumbing; it is leverage.
Why it matters: The single best lens for understanding sanctions as statecraft rather than paperwork.
Extraterritoriality
The reach of one state’s rules beyond its borders — most visibly the US doctrine that any dollar transaction touching US clearing, or any actor dealing with designated parties, can be brought under US jurisdiction. It is why a Swiss bank obeys OFAC and why "secondary sanctions" work without a single US customer.
Why it matters: It explains who actually decides, even inside someone else’s jurisdiction.
The De-Risking Paradox
When compliance costs or fear of penalties make whole categories of customers unprofitable — money-service businesses, NGOs in conflict zones, entire correspondent corridors — banks exit them wholesale. The flows do not stop; they migrate to channels with less oversight. Risk avoidance at the firm level can increase risk at the system level.
Why it matters: The unintended-consequences engine behind much of financial-inclusion and hawala debate.
Regulatory Arbitrage
Structuring activity to fall under the friendliest available rulebook — choosing the member state with the lightest supervisor, the jurisdiction without a travel rule, the licence category with the fewest obligations. Harmonisation projects like MiCA and the EU single rulebook exist precisely to shrink this space; divergence like the EU–Swiss split keeps it open.
Why it matters: Where firms locate, and why regulators harmonise, are both answers to arbitrage.
Same Activity, Same Risk, Same Rules
The technology-neutrality principle regulators invoke to bring novel instruments inside existing perimeters: if a stablecoin functions like e-money, regulate it like e-money. Its counter-principle — that genuinely new structures need genuinely new rules — is the other half of every crypto-regulation debate.
Why it matters: Most regulatory arguments about crypto are this principle and its counter-principle colliding.
Two Clocks
The EU and Switzerland regulate the same industry on separate, unsynchronised tracks: MiCA, TFR and the AML package on one side; FINMA practice, the Swiss AML Act and the transparency register on the other. Treating Swiss firms as MiCA entities — or assuming EU deadlines bind in Zug — is the most common analytical error in DACH coverage.
Why it matters: The premise of the Regulatory Clock page — and of half the Swiss entries below. See the Regulatory Clock →
II The terms — A to Z, filterable
- Agentic AI AI
- AI systems that plan and execute multi-step tasks with limited supervision. In compliance and BD alike, the live question is not capability but accountability: an agent can draft the filing — someone must own it.
- AI in monitoring AI
- Machine-learning models augmenting or replacing rule-based transaction monitoring — promising fewer false positives and typology discovery, at the price of new model-risk and explainability obligations.
- AML / CFT AML / Compliance
- Anti-money-laundering and countering the financing of terrorism: the body of law and practice obliging firms to know their customers, monitor activity, and report suspicion.
- AMLA EU Rules
- The EU Anti-Money-Laundering Authority in Frankfurt: today a coordinator and convergence-driver of national supervisors, from 2028 the direct supervisor of the highest-risk cross-border entities, crypto firms included.
- AMLA-CH (GwG) Swiss Rules
- The Swiss Anti-Money Laundering Act — Switzerland’s own AML statute, revised on its own calendar. Distinct from the EU’s AMLA authority despite the collision of acronyms.
- AMLO-FINMA Swiss Rules
- FINMA’s ordinance detailing how the Swiss AML Act applies in supervised practice — including crypto-specific due-diligence rules. A partial revision is in consultation as of mid-2026.
- AMLR / AMLD6 EU Rules
- The EU AML package’s core: a directly applicable single rulebook (AMLR, applying from 10 July 2027) plus a directive (AMLD6) for what remains national. Together they replace 27 divergent AML interpretations.
- BaFin EU Rules
- Germany’s Federal Financial Supervisory Authority — the licensing gate for German crypto and fintech, and notably stricter than the EU floor (it ended Germany’s MiCA transition six months early).
- Beneficial owner (UBO) AML / Compliance
- The natural person who ultimately owns or controls a customer or transaction, behind however many corporate layers. Transparency registers exist to make this answer checkable.
- Blockchain analytics Crypto
- The discipline (and industry) of clustering addresses, labelling entities and scoring risk from ledger data — increasingly fused with off-chain intelligence. Its outputs are probabilistic evidence, not ground truth.
- Capital controls Geopolitics
- State restrictions on money crossing borders. Crypto is often marketed as their antidote — which is precisely why states with controls police it hardest.
- CASP EU Rules
- Crypto-asset service provider — MiCA’s licensed category for firms offering crypto services in the EU. One authorisation, passportable across all member states.
- CBDC Money Rails
- Central bank digital currency: a direct claim on the central bank in digital form. Politically contested because it hard-codes the question of who may see, and stop, every payment.
- CDD / EDD AML / Compliance
- Customer due diligence — the standard fact-finding behind KYC — and its enhanced form for higher-risk customers (PEPs, high-risk jurisdictions, complex structures), which demands source-of-funds and source-of-wealth answers.
- Chain-hopping Crypto
- Rapidly converting funds across multiple blockchains and assets to defeat tracing. The crypto-native descendant of layering.
- Chokepoint Geopolitics
- A network position everyone must pass through — dollar clearing, SWIFT, a strait, a fab. Control of chokepoints converts economic centrality into coercive power.
- Correspondent banking Money Rails
- The chain of bank-to-bank relationships that moves money across borders where no direct link exists. Each correspondent is a compliance checkpoint — and a potential de-risking exit.
- Cross-chain bridge Crypto
- Infrastructure moving value between blockchains. For investigators, a classic layering point: assets change ledger, ticker and analytic tooling in one hop.
- De-dollarization Geopolitics
- Efforts to reduce dependence on the US dollar and its infrastructure — alternative payment systems, bilateral currency deals, gold reserves. Progress is real but slow: the dollar’s network effects are the product being escaped.
- DeFi Crypto
- Decentralised finance: lending, trading and derivatives run by smart contracts rather than intermediaries. The compliance question it poses is structural — obligations attach to intermediaries, and DeFi claims to have none.
- Designation Sanctions
- The formal act of adding a person, entity, vessel or address to a sanctions list. A designation converts yesterday’s lawful counterparty into today’s prohibited one — retroactive exposure included.
- DLT Act Swiss Rules
- Switzerland’s 2021 distributed-ledger framework, which created ledger-based securities and a DLT trading-facility licence — early evidence of the Swiss preference for adapting existing law over importing EU regimes.
- ESMA EU Rules
- The European Securities and Markets Authority — the EU-level markets regulator that issues MiCA guidance and coordinates national supervisors like BaFin and Austria’s FMA.
- Explainability AI
- The requirement that a model’s decision can be articulated to a regulator, a court, or a customer. In compliance, an unexplainable alert is an unusable one — accuracy alone does not survive an audit.
- False positive AML / Compliance
- An alert that flags legitimate activity as suspicious. At typical rates well above 90%, false positives — not criminals — consume most compliance headcount, which is why reducing them is a business case, not a luxury.
- FATF AML / Compliance
- The Financial Action Task Force — the intergovernmental standard-setter whose 40 Recommendations define global AML/CFT expectations. Not a regulator, but its mutual evaluations and lists move national law.
- Financial statecraft Geopolitics
- The use of financial tools — sanctions, market access, reserves, payment infrastructure — to pursue foreign-policy ends. The reason compliance teams end up implementing foreign policy.
- FINMA Swiss Rules
- The Swiss Financial Market Supervisory Authority — banking, insurance and markets regulator, and the supervisor of Switzerland’s crypto-banks. Swiss firms answer to FINMA practice, not to MiCA.
- FIU AML / Compliance
- Financial Intelligence Unit — the national agency that receives suspicious-activity reports and turns them into intelligence for investigators (MROS in Switzerland, the FIU-Deutschland in Germany).
- Front company Sanctions
- A legitimate-looking firm interposed to hide the true, often designated, party in interest. Beneficial-ownership registers exist largely because fronts work.
- Grandfathering EU Rules
- Transitional permission to keep operating under old rules while a new regime phases in. Every grandfathering window ends with a hard stop — the cliff-edges tracked on the Regulatory Clock.
- Grey list AML / Compliance
- FATF’s "jurisdictions under increased monitoring" — countries with acknowledged AML/CFT deficiencies and a remediation plan. Listing raises the compliance cost of every transaction touching that jurisdiction.
- Hawala AML / Compliance
- Informal value-transfer systems settling through trusted broker networks rather than payment rails. Ancient, efficient, largely invisible to monitoring — and a chronic beneficiary of de-risking.
- KYC AML / Compliance
- Know Your Customer: identifying and verifying who a customer is at onboarding. The front gate of the compliance perimeter.
- KYT AML / Compliance
- Know Your Transaction: continuous monitoring of transaction patterns rather than identities — in crypto, the screening of counterparty addresses and fund flows against risk indicators.
- MiCA EU Rules
- The EU Markets in Crypto-Assets Regulation: the first comprehensive EU-wide licensing and conduct regime for crypto issuers and service providers. Its transition ended 1 July 2026 — see the Regulatory Clock for the dated timeline.
- Mixer / tumbler Crypto
- A service that pools and redistributes funds to break the visible link between source and destination addresses. Some mixers have themselves been sanctioned — designating code and contracts, not just people.
- MLRO AML / Compliance
- Money Laundering Reporting Officer — the named individual personally accountable for a firm’s AML program and its reports. In buying decisions for compliance tooling, usually the economic buyer or veto-holder.
- Model risk AI
- The risk that a model is wrong, drifts, or is misused — managed through validation, monitoring and governance. AI moves compliance failures from "bad rule" to "bad model", which changes who is accountable.
- OFAC Sanctions
- The US Treasury’s Office of Foreign Assets Control — administrator of US sanctions programs and keeper of the SDN List. Its reach extends far beyond US borders via dollar clearing and secondary sanctions.
- On-chain / off-chain Crypto
- On-chain: recorded on a public ledger — transfers, balances, contract calls. Off-chain: everything else — identities, intentions, exchange internals, dark-web context. The boundary between them is where most investigative work happens.
- Passporting EU Rules
- The right to serve the whole EU single market on one member state’s authorisation. The prize that makes an EU licence worth its cost — and unavailable from Switzerland.
- Payment rails Money Rails
- The infrastructure a payment actually travels on — card networks, bank transfer systems, correspondent chains, or blockchains. Who controls the rail controls who may use it.
- PEP AML / Compliance
- Politically exposed person: someone entrusted with prominent public functions, plus family and close associates. Automatically higher-risk — not automatically prohibited.
- Privacy coin Crypto
- A cryptocurrency (e.g. Monero) whose protocol hides amounts and counterparties by design. Widely delisted by regulated exchanges precisely because monitoring cannot see through it.
- Sanctions Sanctions
- State measures restricting dealings with designated countries, entities, persons or sectors — from full embargoes to targeted asset freezes. In finance they function as a prohibition perimeter drawn around counterparties.
- Sanctions evasion Sanctions
- The craft of moving value around a designation: front companies, nested accounts, false documentation, third-country transshipment, chain-hopping. Evasion typologies are the empirical core of enforcement work.
- SAR / STR AML / Compliance
- Suspicious activity / transaction report: the confidential filing a firm must make to its FIU when it suspects illicit funds. Filing is a legal duty; tipping off the customer is an offence.
- SDN List Sanctions
- OFAC’s Specially Designated Nationals list: persons and entities whose assets are blocked and with whom US persons may not deal. Increasingly includes crypto addresses alongside names and passports.
- Secondary sanctions Sanctions
- Measures threatening non-US actors with loss of access to the US system if they deal with primary targets. The mechanism that makes one state’s lists effectively global.
- Self-hosted wallet Crypto
- A wallet controlled directly by its user rather than a regulated intermediary (also "unhosted" or "self-custody"). The regulatory pressure point: rules can bind firms, but keys can be held by anyone.
- Settlement Money Rails
- The moment a payment becomes final and irrevocable. Settlement finality is the legal point of no return — and the reason "instant" user experiences often sit on slow underlying rails.
- SRO Swiss Rules
- Self-regulatory organisation: the Swiss model under which many financial intermediaries meet AML supervision through FINMA-recognised private bodies rather than direct state oversight.
- Stablecoin Money Rails
- A crypto token engineered to hold a fixed value, usually against the US dollar, via reserves or algorithms. Functionally a new dollar rail outside the banking system — which is why regulators treat the large ones as systemic.
- Structuring / smurfing AML / Compliance
- Splitting sums into many small transactions to stay under reporting thresholds. One of the oldest typologies, and the reason thresholds alone never suffice.
- SWIFT Money Rails
- The Belgian cooperative whose messaging network coordinates most cross-border interbank payments. It moves instructions, not money — which is exactly why disconnection from it is such an effective sanction.
- Terrorist financing AML / Compliance
- Funding terrorism — often with small, individually innocuous amounts, which inverts the AML problem: the money is frequently clean until the moment of use.
- Trade-based ML AML / Compliance
- Laundering value through mispriced, misdescribed or phantom trade flows. Considered one of the largest and least-detected laundering channels because the money moves as commerce.
- Transaction monitoring AML / Compliance
- The automated surveillance of customer activity against rules and models, generating alerts for human review. Its economics are dominated by the false-positive rate.
- Transparency register (TLPA) Swiss Rules
- Switzerland’s federal register of beneficial owners under the new Transparency of Legal Persons Act, in force from 1 October 2026 — the Swiss clock’s next hard date.
- Travel Rule Crypto
- The FATF requirement — in the EU, Regulation 2023/1113 — that originator and beneficiary information accompany crypto transfers between service providers, mirroring wire-transfer rules.
- VASP Crypto
- Virtual asset service provider — FATF’s umbrella term for exchanges, custodians and transfer services in crypto. The global hook on which national licensing regimes hang.
- Wallet Crypto
- Software or hardware controlling the cryptographic keys that authorise transactions. The wallet holds keys, not coins; whoever holds the keys holds the money.
Nothing inside the perimeter matches that — try another word or clear the filter.
Method, scope & corrections
Scope follows the publication, not the dictionary: entries earn their place by recurring in Perimeter Reports, the Regulatory Clock, or the field this publication covers. Deliberately excluded: trading jargon, deep protocol engineering, and anything whose definition would expire — dated obligations live on the Clock, which is re-verified monthly. Regulatory entries follow the primary texts (MiCA,AMLR,FATF Recommendations,OFAC,FINMA); “weaponized interdependence” followsFarrell & Newman (2019). Definitions are the author’s own wording and judgment, not legal advice. Spotted an error or a missing term that belongs here? Tell me — corrections are published, not buried.