What are the AML obligations of a US crypto exchange?
A convertible-virtual-currency exchanger or administrator is a Money Services Business under FinCEN's regulations (31 CFR §1010.100(ff)) and must register, implement an AML programme, file CTRs and SARs, and comply with the BSA travel rule (USD 3,000 threshold). State money-transmitter licensing applies in addition. SEC and CFTC have separate regimes where the asset is a security or commodity.