Regulatory Compliance of Multi-Chain Wallet Tracking Solutions: Navigating AML/KYC in a Cross-Chain World

KEY TAKEAWAYS

• Wallet tracking solutions monitor wallet activity across multiple blockchains, linking addresses to real-world entities and identifying suspicious patterns.
• In the UAE, VARA and FSRA enforce AML/KYC regulations for Virtual Asset Service Providers (VASPs), focusing on CDD, transaction monitoring, and Travel Rule compliance.
• Wallet tracking platforms help meet these regulations by attributing wallet addresses to known entities, enabling real-time transaction monitoring, and triggering alerts for suspicious activities.
• The UAE is becoming a hub for advanced compliance solutions, with technologies like Zero-Knowledge KYC and Self-Sovereign Identity expected to transform identity verification.
• The future of compliance in the UAE will balance on-chain privacy with off-chain accountability, support transparency and user privacy, and address emerging challenges in digital assets.

INTRODUCTION – MULTI CHAIN WALLET TRACKING SOLUTIONS

Wallet-tracking solutions are blockchain analytics tools that monitor and analyse the activity of cryptocurrency wallets across one or more blockchain networks. These platforms identify wallet addresses, trace transaction histories, and map relationships between wallets and entities. By aggregating this data, they can flag suspicious patterns like sudden asset movements across chains, interaction with mixers, or links to known illicit addresses. Some advanced tools even assign risk scores to wallets and offer insights into the behaviour of both individual users and institutions. In a multi-chain environment, wallet trackers help decode the flow of funds across ecosystems like Ethereum, Solana, or BNB Chain, offering transparency in an otherwise pseudonymous financial space.

OVERVIEW OF REGULATORY COMPLIANCE IN THE UAE

Through regulators like the Virtual Assets Regulatory Authority (“VARA“) in the Emirate of Dubai and the Financial Service Regulatory Authority (“FSRA“) in the Abu Dhabi Global Market (“ADGM“), UAE enforces clear AML/KYC obligations on Virtual Asset Service Providers (“VASPs“). These legal mandates are rooted in three core pillars:

• Customer Due Diligence (“CDD” ): CDD requires identity verification and risk profiling during onboarding.
• Ongoing Transaction Monitoring: This step mandates VASPs to flag suspicious on-chain behaviour in real-time.
• Travel Rule Compliance: This step ensures that the sender and recipient information accompanies crypto transfers[1].

How Can Wallet Tracking Platforms Help?

Wallet tracking platforms such as Chainalysis, Elliptic, and Cielo are engineered to address the compliance pain points outlined above—especially in multi-chain transactions and pseudonymous wallets. Here’s how they help VASPs meet UAE’s regulatory requirements:

1. CDD and Address Attribution: To fulfil onboarding and identity verification obligations, wallet trackers use blockchain analytics to attribute wallet addresses to known entities like centralised exchanges, mixers, or sanctioned actors. These platforms help compliance teams assess user risk levels by analysing historical transaction behaviour, wallet clustering, and connections to high-risk networks. A key tool here is the address attribution engine, which maps wallets to real-world identities or risk categories based on behavioural patterns and entity links[2].
2. Real-Time Transaction Monitoring: Wallet trackers continuously scan the blockchain to detect suspicious behaviour—like abnormal transaction sizes, rapid asset movements, or signs of layering and structuring. Alerts are triggered for potential red flags, enabling timely filing of Suspicious Activity Reports (SARs) with the UAE’s Financial Intelligence Unit (FIU)[3].
3. Risk Scoring & Profiling: These platforms use machine learning and historical data to assess wallet behaviour over time, assigning risk scores that align with VASP risk-based frameworks. This allows for enhanced due diligence on high-risk profiles, a requirement under VARA and FSRA regulations.
4. Travel Rule Alignment & Cross-Chain Correlation: Platforms support Financial Action Task Force (“FATF”) travel rule compliance by helping identify both the sender and receiver in virtual asset transfers. In cases where users attempt to obscure transfers across chains (via bridges or mixers), wallet-tracking tools correlate addresses and transactions across multiple networks—effectively unmasking the transactional trail and ensuring that travel rule data can be reconstructed or verified.

Wallet Tracking Solutions in Action: A Case Study

A recent example is Elliptic’s investigation into Garantex[4], a crypto exchange linked to illicit fund flows from ransomware and darknet markets. Elliptic was able to trace these transactions across multiple chains—including Bitcoin, Ethereum, and TRON—demonstrating how multi-chain analytics can uncover hidden connections. By combining blockchain data with off-chain intelligence (like forum leaks), Elliptic helped law enforcement link anonymous wallets to real-world actors. This kind of cross-chain visibility is exactly what regulators expect under frameworks like the FATF recommendations and the European Union’s Anti-Money Laundering Directive.

CHALLENGES OF MULTI-CHAIN COMPLIANCE

Wallet-tracking platforms are essential for regulatory compliance, yet they face significant challenges in the evolving multi-chain landscape. Cross-chain asset transfers through decentralised bridges obscure transaction origins, making it harder to trace funds accurately[5]. Additionally, regulatory arbitrage i.e., where users exploit differences in global AML/KYC standards creates enforcement blind spots. Privacy-enhancing tools like Tornado Cash and Monero further mask transaction trails, while the lack of universal on-chain identity standards limits the ability to link pseudonymous wallets to real-world entities, complicating KYC and compliance efforts[6].

CONCLUSION AND WAY FORWARD

As the UAE continues to emerge as a global hub for digital assets, it is expected to serve as a testing ground for advanced regulatory compliance tools that balance innovation with oversight. Technologies such as Zero-Knowledge KYC (“zk-KYC”)[7], which allows users to prove compliance without revealing sensitive information, and Self-Sovereign Identity (“SSI”)[8], where individuals manage and selectively disclose their digital credentials, are poised to redefine identity verification. Moreover, UAE-based DeFi projects may begin integrating on-chain compliance layers to meet regulatory thresholds, especially when targeting institutional users or dealing with tokenised assets.

The future of compliance in the UAE is set to blend on-chain privacy with off-chain accountability, creating a model where legal frameworks and technical innovation reinforce each other. In this rapidly evolving landscape, regulatory compliance is not a barrier but a cornerstone for sustainable growth. Multi-chain wallet tracking solutions are already aiding VASPs, DeFi platforms[9], and regulators in achieving a balanced approach that upholds transparency, mitigates risks and protects user privacy.

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[1] ‘Anti-Money Laundering and Countering Financing of Terrorism | Rulebook’ <https://en.adgm.thomsonreuters.com/rulebook/anti-money-laundering-and-countering-financing-terrorism-2> accessed 7 April 2025.

[2] ‘Crypto Tracing | TRM Glossary’ <https://www.trmlabs.com/glossary/crypto-tracing#what-are-some-common-tools-and-technologies-used-in-crypto-tracing-1> accessed 7 April 2025.

[3] ‘Real-Time Transaction Monitoring to Prevent Fraud – Sanction Scanner’ (15 July 2024) <https://www.sanctionscanner.com/blog/the-importance-of-real-time-transaction-monitoring-in-preventing-fraud-930> accessed 7 April 2025.

[4] Elliptic, ‘Elliptic in Action: Uncloaking Garantex for Law Enforcement and Sanctions Compliance’ <https://www.elliptic.co/blog/elliptic-in-action-garantex> accessed 7 April 2025.

[5] ‘Track and Trace: Automatically Uncovering Cross-Chain Transactions in the Multi-Blockchain Ecosystems’ <https://arxiv.org/html/2504.01822v1> accessed 7 April 2025.

[6] ‘Tornado Cash Ruling Impact on Monero and Privacy Coins – OneSafe Blog’ <https://www.onesafe.io/blog/tornado-cash-ruling-monero-privacy-coins-impact> accessed 7 April 2025.

[7] ‘Zero-Knowledge KYC | Galactica Network Dev Documentation’ (7 May 2024) <https://docs.galactica.com/galactica-developer-documentation/galactica-concepts/zero-knowledge-kyc> accessed 7 April 2025.

[8] ‘Self-Sovereign Identity: The Ultimate Guide 2025’ <https://www.dock.io/post/self-sovereign-identity> accessed 7 April 2025.

[9] Chainalysis Team, ‘Chainalysis Launches Enhancements to Help Organizations Know Your VASP’ (Chainalysis, 4 February 2025) <https://www.chainalysis.com/blog/chainalysis-launches-enhancements-helping-organizations-know-your-vasp/> accessed 7 April 2025.