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FATF Report Summary: Targeted Report on Stablecoins and Unhosted Wallets - Peer-to-Peer Transactions

Core Content

The FATF report provides an in-depth analysis of the risks, threats, and vulnerabilities associated with stablecoins and unhosted wallets, particularly in the context of peer-to-peer (P2P) transactions. It outlines the current state of the stablecoin ecosystem, the increasing use of stablecoins in illicit activities, and the good practices that can be adopted to mitigate these risks.

Main Points

1. Stablecoin Overview

• Definition: A stablecoin is a type of virtual asset that aims to maintain price stability, often by linking its value to fiat currencies, other virtual assets, or through algorithmic mechanisms.
• Types:
  • Fiat-backed: Backed by physical assets like USD, dominate the market.
  • VA-backed: Backed by other virtual assets, often over-collateralised.
  • Algorithmic: Maintain stability through supply adjustments without backing assets.

2. Market Growth

• As of mid-2025, over 250 stablecoins were in circulation, with a total market capitalisation exceeding USD 300 billion.
• Daily trading volumes surpass those of Bitcoin.
• Centralised stablecoins account for 90% of the market, with fiat-backed stablecoins representing 95% of total market capitalisation.

3. Illicit Use of Stablecoins

• Stablecoins are increasingly used for money laundering (ML), terrorist financing (TF), and proliferation financing (PF).
• In 2025, stablecoins accounted for 84% of USD $154 billion in illicit virtual asset transaction volume, surpassing Bitcoin.
• Threat actors use stablecoins in both primary and secondary markets to obscure the origin of funds and facilitate cross-border transactions.
• Unhosted wallets are a key vulnerability due to their lack of AML/CFT oversight, allowing P2P transactions to bypass regulatory checks.

4. Threat Actors and Activities

• DPRK: Uses stablecoins (e.g., USDT on Tron) for weapons procurement and sanctions evasion, often through OTC brokers and P2P platforms.
• Drug Trafficking Organisations (DTOs): Utilise stablecoins for illicit transactions, often via unlicensed VASPs.
• Terrorist Financiers: Rely on stablecoins to move funds discreetly and efficiently.
• Iran: Leverages stablecoins to finance proliferation, including the purchase of drone components and high-tech equipment.

5. Vulnerabilities

• Unhosted Wallets: Allow for high-risk P2P transactions without intermediaries, increasing the potential for misuse.
• Interoperability and Liquidity: Enable seamless cross-border transfers and integration with traditional finance, making stablecoins attractive for illicit activities.
• Data Limitations: There is limited data on the broader use of stablecoins for goods and services, especially in P2P contexts.

6. Good Practices for Mitigation

• Legal Frameworks: Establish comprehensive legal frameworks in compliance with FATF standards.
• AML/CFT Obligations: Apply clear AML/CFT requirements to stablecoin issuers, intermediaries, and custodians.
• Risk Assessment: Implement risk mitigation measures for transactions involving unhosted wallets.
• Technology Tools: Use advanced tools for detecting and monitoring suspicious transactions.
• Public-Private Collaboration: Encourage coordination between authorities and the private sector.
• Technical Assistance: Provide support to jurisdictions that lack adequate regulatory frameworks.

Key Recommendations

• Jurisdictions should continue monitoring the adoption of stablecoins and their use in P2P transactions.
• Enhanced oversight of unhosted wallets and the development of accurate data on transaction volumes is crucial.
• Encourage the use of programmable smart contracts for freezing or denying access to stablecoins in secondary markets.
• Strengthen cooperation between national and international authorities to combat illicit finance.

Annex A: Risk Indicators

• The report includes a list of risk indicators for identifying misuse of stablecoins, particularly through unhosted wallets.

Conclusion

The FATF report underscores the growing role of stablecoins in both legitimate and illicit financial activities. It highlights the need for enhanced regulatory measures, technological innovation, and international cooperation to mitigate the risks associated with their use, especially in P2P transactions. The report serves as a guide for jurisdictions and stakeholders to better understand and address these challenges.