Privacy Policies for Crypto Exchanges: KYC, Wallets, AML
Build a compliant privacy policy for crypto platforms covering KYC data, wallet and transaction records, and AML duties, with practical, global guidance.
As a crypto exchange, your privacy policy must explain why and how you collect KYC data and identity documents. Specify the lawful basis (e.g., GDPR Art. 6(1)(c) legal obligation) and required notices (GDPR Arts. 13-14; California CPRA Cal. Civ. Code 1798.100 et seq.). Limit fields to what AML laws require, secure uploads, and verify vendors processing KYC. Define retention (BSA/FinCEN typically 5 years) and cross-border transfer safeguards (GDPR Chapter V). LegalDocs.ai can generate tailored disclosures and map processors and subprocessors to keep your records of processing current.
Wallet addresses and transaction records can constitute personal data when linkable to a person. Make this explicit, describe analytics and blockchain forensics vendors, and avoid putting personal data on-chain. Maintain off-chain references, salt/hash cautiously (hashing is not anonymization), and set separate retention for logs and blockchain analytics. Meet travel rule obligations (FATF Rec. 16; US 31 CFR 1010.410(f); EU Transfer of Funds Regulation (EU) 2023/1113) by disclosing originator and beneficiary data sharing. LegalDocs.ai helps document data flows and draft purpose-specific notices.
AML compliance must align with privacy. If you are a US MSB, implement a written AML program and Customer Identification Program under 31 CFR 1022.210; keep required records for five years (31 CFR 1010.410), file SARs (>= $2,000) and satisfy OFAC screening (31 CFR parts 500). In the EU, align with 5AMLD/6AMLD and national transpositions. Use access controls, role-based retention, and GDPR Art. 23 notices where rights are restricted. LegalDocs.ai provides policy templates, DPIA checklists, and retention schedules you can operationalize quickly.