出典確認済みリサーチ: FATF Stablecoin Unhosted Wallet

Decision Matrix

Source Map

• FATF: Targeted report on Stablecoins and Unhosted Wallets - Peer-to-Peer Transactions (fatf-stablecoins-unhosted)
• FATF: New FATF report highlights illicit finance risks linked to Offshore VASPs (fatf-offshore-vasps)
• FATF: FATF urges action to respond to emerging risks from Decentralised Finance (fatf-defi-2026)
• FATF: FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets (fatf-2025-va-vasp-update)

Control Notes

1. Counterparty type

Counterparty type is the point where public documentation must become an operating rule. In this package, it means the route may involve a VASP, offshore VASP, issuer, DeFi arrangement or unhosted wallet. The practical action is to classify the actor before applying a Travel Rule or sanctions control. The unresolved edge is whether a front-end hides the actual operator, so the article keeps that edge explicit instead of turning it into a reward claim, licensing claim, approval claim, safety guarantee, recovery promise, platform ranking or price implication.

2. Wallet custody

Wallet custody is the point where public documentation must become an operating rule. In this package, it means unhosted-wallet P2P activity can bypass regulated intermediaries. The practical action is to record whether transfer information is collected by a VASP or not. The unresolved edge is whether the sender controls the wallet or uses a service wrapper, so the article keeps that edge explicit instead of turning it into a reward claim, licensing claim, approval claim, safety guarantee, recovery promise, platform ranking or price implication.

The operating test is narrow.

3. Issuer control

Issuer control is the point where public documentation must become an operating rule. In this package, it means stablecoin issuer control may not cover every cross-chain activity path. The practical action is to identify issuer, chain, bridge and freeze or redemption terms separately. The unresolved edge is whether wrapped or bridged tokens inherit issuer controls, so the article keeps that edge explicit instead of turning it into a reward claim, licensing claim, approval claim, safety guarantee, recovery promise, platform ranking or price implication.

The operating test is narrow.

4. Offshore VASP exposure

Offshore VASP exposure is the point where public documentation must become an operating rule. In this package, it means offshore providers can create supervisory blind spots. The practical action is to check licensing, registration, jurisdiction and public enforcement context. The unresolved edge is whether the counterparty is merely marketed as global, so the article keeps that edge explicit instead of turning it into a reward claim, licensing claim, approval claim, safety guarantee, recovery promise, platform ranking or price implication.

The operating test is narrow.

5. DeFi control point

DeFi control point is the point where public documentation must become an operating rule. In this package, it means some DeFi arrangements may have identifiable governance, interfaces or operators. The practical action is to separate smart contract, UI, DAO, admin key and liquidity route. The unresolved edge is whether control exists but is undisclosed, so the article keeps that edge explicit instead of turning it into a reward claim, licensing claim, approval claim, safety guarantee, recovery promise, platform ranking or price implication.

The operating test is narrow.

6. Action condition

Action condition is the point where public documentation must become an operating rule. In this package, it means policy context is not private account permission. The practical action is to pause if identity, Travel Rule data, sanctions screening, issuer terms or recovery route is unclear. The unresolved edge is whether support can resolve an exception after funds move, so the article keeps that edge explicit instead of turning it into a reward claim, licensing claim, approval claim, safety guarantee, recovery promise, platform ranking or price implication.

The operating test is narrow.

Known Unknowns

• whether a front-end hides the actual operator
• whether the sender controls the wallet or uses a service wrapper
• whether wrapped or bridged tokens inherit issuer controls
• whether the counterparty is merely marketed as global
• whether control exists but is undisclosed
• whether support can resolve an exception after funds move

Practical Takeaway

FATF material makes stablecoin and wallet routing a counterparty-control problem rather than a generic crypto label. FATF’s 2026 stablecoins and unhosted-wallet report says P2P transactions through unhosted wallets can occur without a regulated intermediary VASP or financial institution, and it highlights stablecoin issuer challenges around cross-chain activity. Its offshore-VASP and DeFi publications add that supervisory blind spots and qualifying DeFi arrangements remain implementation risks. The decision outcome is to identify whether a route involves a VASP, offshore VASP, issuer, unhosted wallet, DeFi control point or Travel Rule obligation before treating a transfer as low-risk. The article stops at the evidence boundary. It helps the reader decide what to inspect next without converting public documentation into a promise that a private account, wallet, API key, pool route, stablecoin balance, tokenized asset or policy framework will work under every future condition.