During a five‑day workshop in Nairobi, United Nations Office on Drugs and Crime brought together investigators, regulators and virtual asset service providers to run simulated investigations. The exercise showed that the main bottleneck in crypto‑related financial crime cases is not technology, but the lack of joint training on how to request and use evidence from regulated providers.
FATF’s July 2026 global review noted that 83% of jurisdictions have passed Travel Rule legislation, yet organised crime groups continue to move billions through the gaps that remain between policy on paper and investigators’ practical knowledge. Kenya, where the training took place, has enacted a Virtual Asset Service Providers Act in 2025 and is actively working to close this gap.
A licensed virtual asset provider sits at the intersection of identity‑linked real‑world evidence and the on‑chain trail that blockchain explorers produce. Neither side alone can provide the full picture: banks lose visibility when funds convert to crypto, and blockchain data cannot identify wallet owners without a regulated entity’s input. The partnership between banks and providers is therefore critical.
Chainalysis’s 2026 Crypto Crime Report found that illicit activity remains below 1% of all on‑chain transaction volume, unchanged from 2025, despite growing crypto adoption. The issue is not the opacity of crypto, but the missing bridge between evidence holders and investigators trained to ask for it correctly.
In Nairobi, a key moment was when a provider demonstrated that a well‑structured request—focused on a specific hypothesis such as “did the subject control this account?”—could be acted on quickly, whereas vague or incorrectly framed requests stalled the investigation. The clarity of the request hinges on distinguishing preservation, disclosure and freezing as separate actions, each with its own legal basis.
These challenges are not unique to Kenya. Investigators worldwide, from Accra to London to São Paulo, face the same question: how to connect on‑chain activity to reliable, identity‑linked evidence in a lawful and timely manner. The underlying gap between what providers can offer and what investigators are trained to ask for exists in almost every jurisdiction still developing its virtual asset framework.
To address this, the author will carry the conversation to West Africa later this month, convening a workshop for GIABA member states on implementing FATF Recommendation 15 across eleven countries at different stages of regulatory development. The goal is to bring regulators, law enforcement and licensed providers into the same room before case volumes force coordination, teaching investigators what providers hold and what they do not, and walking them through the full lifecycle of a request.
Without this proactive, joint training, jurisdictions risk having their first major fraud or laundering case expose the limits of their investigative capabilities, setting a poor precedent. The solution is straightforward: align obligations in both directions, ensuring private sector participation in rule‑making and public authority understanding of practical mechanics.
