Bitgo on Providing Secure AML/KYC Compliance for Cryptocurrency

DECEMBER 2020

FEATURE STORY — 7 BitGo On Providing Secure AML/KYC Compliance For Cryptocurrency

NEWS & TRENDS — 11 56 percent of cryptocurrency exchanges have weak or nonexistent KYC guidelines

DEEP DIVE — 19 Tamping down on cryptocurrency exchange cybercrime with AML/ KYC compliance Table Of CONTENTS

WHAT’S INSIDE DEEP DIVE

A look at recent AML and KYC An in-depth examination of the developments, including $2.8 billion skyrocketing cybercrime on 3 laundered through cryptocurrency 19 cryptocurrency exchanges and the exchanges and the government and pressures they are facing from world private efforts intended to stop it governments and regulators to step up their AML and KYC processes FEATURE STORY ABOUT

An interview with Anthony Botticella, Information on PYMNTS.com 7 CEO of BitGo Trust, about how the 22 and Trulioo company deploys a multilayered AML/ KYC system to prevent and monitor for suspicious activity on its platform

NEWS & TRENDS ACKNOWLEDGMENT The AML/KYC Tracker® was done in collaboration The latest headlines from the with Trulioo, and PYMNTS is grateful for the space, including Metal Pay’s recent company’s support and insight. PYMNTS.com 11 retains full editorial control over the following partnership with Trulioo to help root findings, methodology and data analysis. out money launderers and why 56 percent of cryptocurrency exchanges don’t follow KYC guidelines WHAT’S INSIDE What’s INSIDE

oney laundering is a global however, with experts predicting that plague, with the estimated cryptocurrency-related crimes totaled $4.3 bil- amount in a given year ranging lion in 2019, including $2.8 billion in laundered from $800 billion to $2 trillion money. This is up from just $1 billion laundered M— or anywhere from 2 percent to 5 percent in 2018, and the problem is expected to con- of the global gross domestic product (GDP). tinue its rise as cryptocurrencies become more The growing popularity of online banking popular, valuable and commonly accepted has also pushed money laundering into the among merchants. digital realm as drug dealers, terrorists or human traffickers who might once have set Governments around the world are crack- up brick-and-mortar businesses to launder ing down on cryptocurrency exchanges’ lax their ill-gotten funds can conduct the same anti-money laundering (AML) and know your operations today completely virtually, even customer (KYC) procedures, both of which establishing multiple websites as backups in could result in a serious dent in money launder- case authorities catch on. ing activities if they were deployed effectively. One particularly common avenue for money Many cryptocurrency exchanges are deny- laundering is through cryptocurrency — a bur- ing that such a problem exists at all — and are geoning market expected to be valued at $1.4 subsequently reaping harsh fines and even jail billion by 2024. Its skyrocketing popularity time for their owners as a result — but others obscures an ever-expanding web of money are working on improving their AML procedures laundering schemes and other cybercrimes, with the help of third-party partners.

The very nature of cryptocurrencies means 56 percent of these professionals saying that that they will likely always be a viable avenue money laundering is a significant issue and for money laundering, but risk levels could 48 percent opining that it is being sufficiently potentially be reduced with diligence on the fought at exchanges. parts of both government regulators and the The cryptocurrency industry is not the only exchanges themselves. one facing AML/KYC difficulties, however, with traditional financial institutions (FIs) also Around the AML and KYC world reporting struggles with these processes. Part of what is fueling money laundering Forty-seven percent of American banks and and other cybercrime on cryptocurrency 40 percent of European banks declared in exchanges is that the majority of these another recent study that regulatory compli- exchanges have few methods in place for ver- ance is their primary challenge in 2020. This is ifying their users. One recent study found that chiefly due to the fact that customer onboard- 56 percent of cryptocurrency exchanges have ing is done by a large number of smaller, weak or nonexistent KYC systems that do little fragmented teams rather than a single dedi- to prevent money laundering. Many exchanges cated workforce. deliberately obfuscate their country of origin to avoid having to comply with any sort of KYC For more on these stories and other AML and guidelines at all, exacerbating the money laun- KYC developments, read the Tracker’s News dering problem. and Trends section (p. 11).

This lack of sufficient KYC processes at many How BitGo’s AML/KYC protocols detect cryptocurrency exchanges is generating an and prevent suspicious activity absence of trust from banks and government Protection of client assets is just as para- regulators. A recent joint survey revealed that mount in the cryptocurrency industry as it is 88 percent of financial experts say that cryp- in traditional finance. Digital asset financial tocurrencies aid in money laundering and only services providers like BitGo Trust have devel- 9 percent feel that the sector is combating this oped multilayered protocols for AML/KYC to the best of its ability. Players in the crypto- compliance as a single layer of security is not currency market disagree, however, with only

nearly adequate. In this month’s Feature Story (p. 7), PYMNTS talked with Anthony Botticella, CEO of BitGo Trust, about how the company leverages ID verification and behind-the- scenes transaction analysis to stop bad actors in their tracks.

Deep Dive: Enforcing AML/KYC compliance at cryptocurrency exchanges

Billions of dollars flow around the world in cryptocurrency transactions, with their anon- ymous nature making them a prime way for money launderers to conduct their crimes. The cryptocurrency exchanges themselves are often reluctant to step up their AML procedures to prevent this, but government oversight authorities are cracking down on noncompliant marketplaces. This month’s Deep Dive (p. 19) explores the various ways that money launderers exploit cryptocurrencies and examines the actions that regulators are taking to reduce the spread of cybercrime on these platforms.

FIVE VERIFICATION

Less than half of all FAST cryptocurrency exchanges have FACTS functional KYC systems. REGULATION DISTRUST

FinCEN has fined the owner of Banks are growing increasingly two cryptocurrency websites $60 distrustful of cryptocurrency million for AML violations. exchanges’ AML procedures, while the exchanges maintain they are used for valid reasons.

TEAMWORK COMPLIANCE

The EU is forming a new regulatory Bank compliance staff are finding agency to monitor member states’ it progressively more difficult to AML procedures and ensure they meet AML/KYC regulations due to are up to continent-wide standards. the distribution of this work among multiple unsynchronized teams.

7 FEATURE STORY

“Crypto is still a very new industry,” Anthony BITGO ON Botticella, CEO of BitGo Trust, said in a recent PROTECTING interview with PYMNTS. “Some of the players CRYPTOCURRENCY that are coming up may not understand all the requirements. So, we take a very educational EXCHANGES FROM approach when dealing with clients and we MONEY LAUNDERERS have to explain what we’re asking for, why we’re doing it and how we’re going to be compliant with U.S. regulations.” There are currently more than 5,500 different BitGo’s AML procedures incorporate both a cli- cryptocurrencies in circulation, but the biggest ent authentication system at the point of sign-up name in the business — and often a metonym and a back-end analysis system that identifies for the industry itself — is bitcoin. The year and flags suspicious transactions that could 2020 saw 18.42 billion bitcoins in circulation, indicate money laundering. with a market capitalization of $117.81 billion

and an individual coin valued at $19,463 as of Verification at the point of entry December. These coins often change hands, The first step to detecting and preventing either through cryptocurrency exchanges or money laundering begins at the point of entry, via digital asset financial services providers when new customers sign up for accounts with like BitGo Trust. BitGo. All new customers must undergo a rigor- Many cryptocurrency exchanges have faced ous KYC process to ensure they are not known challenges for suspicious activities, such as money launderers by cross-referencing several money laundering, but BitGo Trust, a division of points of personal information. BitGo Holdings, is regulated by the South Dakota “We run [new customers] through our screening Division of Banking and leverages the same tool to make sure that they don’t hit any [Office onboarding protocols for AML/KYC practices as of Foreign Assets Control] or other sanctions traditional financial institutions. lists as well as background searches and veri- fying their identities using a government-issued

ID, like a driver’s license, [along with] proof of Transaction monitoring behind the residency,” Botticella said. “Then we also require scenes our clients to do an onboarding call, so it’s an The second step of BitGo’s AML procedure is actual person versus somebody doing it anony- a transaction monitoring algorithm that reviews mously on the internet and having documents. the funds moving in and out of accounts to Everybody does a video verification as well.” determine if they are received from or sent to

All customers are subject to a pre-KYC call to any suspicious destinations, such as dark web ensure they understand the requirements for marketplaces. This is supplemented by peri- opening up an account before this process odic reviews of all transactions to check for even begins. The process is often more difficult unusual behavior.

for foreign customers, who may not understand “We conduct annual reviews of our clients as U.S. compliance regulations or have the neces- required by regulators,” said Botticella. “If nec- sary equivalent documents for verification. essary, we’ll go back to the client, reverify who’s “The biggest thing is document translation: on the account, what they’re doing and if any of What we may call articles of incorporation, their business purposes have changed.” they may call something else,” he explained. “A country may have an ID that doesn’t expire, for example. We [have to] learn every different country’s rules and regulations of what’s an acceptable document, what their passports and driver’s licenses look like, certain things like that.”

The KYC process at the point of account cre- ation is only the first line of defense, however. Ongoing monitoring of existing accounts is also necessary to ensure that cryptocurrency exchanges like BitGo are continuously compliant with AML regulations.

A country may have an ID that doesn’t expire, for example. We [have to] learn every different country’s rules and regulations of what’s an acceptable document, what their passports and driver’s licenses look like.

Any large transaction that is not in client trans- that, we’ll reach back out and ask what this action history may warrant further exploration, transaction is about, as it is not in line with [their] as is the case at all financial institutions. normal scope of business,” he noted. “If their business has changed in the last six months “Similarly, we may reach out to the client to and led to a transaction volume change, we’ll determine the reason for the transaction for want to know the business case for that: ‘How both the client’s and BitGo’s protection.” has that changed? Where are the sources of Warning signs for suspicious activity largely those funds?’” revolve around transaction values, he said. Any The double-layered AML/KYC system is crucial unusually large payment is cause for suspicion, for ensuring that all BitGo customers remain at which point BitGo will personally check in aboveboard and that money launderers can- with the customer to find out its purpose. not go undetected on its service. Any single “During onboarding we’ll ask what they think defensive layer is difficult to get around, but cir- their transaction volume is, and if it exceeds cumventing both is next to impossible.

AML/KYC TRENDS

More than half of cryptocurrency These deficient exchanges are located around exchanges have weak or no KYC systems the world, with Russia, the United Kingdom and the United States having the highest num- Proper AML/KYC procedures are critical when ber with lax KYC protocols. Seychelles is also a conducting transactions to ensure that custom- potential nest for money laundering, with 85 per- ers are who they say they are and that the funds cent of the country’s exchanges failing to have in question are not being used for illicit pur- proper KYC processes. poses. A whole segment of transacting services

misses the mark on these crucial processes, Financial decision-makers have low trust however: cryptocurrency exchanges. A recent in automated AML systems, study finds study found that 56 percent of these exchanges AML automation is a breakthrough technology do not follow any sort of KYC guidelines, result- for many businesses, enabling them to be coming in weak or nonexistent verification systems pliant with federal regulations while avoiding the that do little to prevent money laundering. Many tedious and expensive manual effort of inspect- of the exchanges with weak systems fail to men- ing every transaction for potential violations. tion any country of origin on their websites or A recent study found that 47 percent of senior in any of their terms and conditions, apparently decision-makers at a variety of companies have in a deliberate attempt to avoid adherence to some level of distrust in automated authentica- any regulations. tion procedures, however, with 21 percent saying

that they do not trust them at all. This distrust saying they fully trust automated systems. Most is reflected in usage rates among businesses, businesses use some form of automated cus- 23 percent of which lack any sort of automated tomer authentication due to its cost-saving AML processes. nature, however, with almost 80 percent of businesses now utilizing electronic AML checks. Accountants tend to have more trust in automation than most career fields, with 32 percent

NEW CRYPTOCURRENCY KYC INNOVATIONS

Metal Pay integrates Trulioo onboarding Almost solution for fast account opening, AML/ KYC compliance

Some cryptocurrency players are meeting demand for improved AML/KYC compliance by partnering with third-party providers to more effectively onboard their users. One example 80% is U.S.-based cryptocurrency exchange platform Metal Pay, which recently teamed up of businesses now with Trulioo to integrate the latter’s onboarding solution to comply with the strict AML/KYC reg- utilize electronic ulations required for money service providers of all types. Metal Pay needed a solution that was able to function in multiple global markets AML checks. and had the capacity for quick expansion while simultaneously providing customers with faster experiences, according to Trulioo. Metal Pay currently operates in 24 countries and is compatible authentication program to ensure that bad with more than 30 different cryptocurrencies. actors cannot set foot on its platform and use it for money laundering, according to its chief BitMEX strengthens AML measures in compliance officer, Malcolm Wright. Existing wake of criminal noncompliance charges users who do not complete the platform’s new Another cryptocurrency trading platform aiming KYC program will be unable to withdraw funds to improve its AML/KYC procedures is bitcoin after December 4. exchange BitMEX, which recently implemented This implementation comes soon after the U.S. a new risk assessment system to oversee Commodity Futures Trading Commission lev- trades and scan them for potential malfeasance. eled charges against BitMEX for violating AML The exchange also plans to unveil a new user

regulations and operating as an unregistered FinCEN further alleges that the owner adver- trading platform. The Department of Justice also tised his sites’ mixing services on various dark charged BitMEX with violating the Bank Secrecy web forums, marketing his business to narcotics Act by failing to implement AML and KYC mea- traffickers, counterfeiters and other fraudsters. sures, which the platform hopes to improve Just one of his exchanges processed $311 mil- with its new system. The legal proceedings are lion through 365,000 transactions between still ongoing, but BitMEX has so far denied the June 2014 and December 2017, FinCEN noted allegations. in its report. The owner will face federal criminal charges in addition to the fine, including money REGULATORS CRACK DOWN ON laundering, operating an unlicensed money CRYPTOCURRENCY KYC transmitting business and conducting money transmission without a license. FinCEN fines two bitcoin mixing websites $60 million for AML violations Cryptocurrency exchanges met with One common practice among cryptocurrency growing distrust by banks, study finds users is “mixing,” in which users mix their cur- Cryptocurrencies have skyrocketed in popular- rencies in a pool with other users and then ity since bitcoin was introduced 11 years ago, withdraw the same amount they put in to with a variety of names like ethereum and doge- obscure the link between their blockchain iden- coin joining the space in subsequent years. They tifiers and their real-life identities. These mixing may be well-known among tech-savvy consum- websites are still subject to the AML/KYC laws ers, but a sense of distrust for virtual currencies imposed on exchanges, however, as the owner is growing among established FIs, according of two mixing services recently found out when to a recent joint survey of financial experts by the U.S. Treasury Department’s Financial Crimes ACAMS, RUSI and YouGov. A full 88 percent Enforcement Network (FinCEN) fined him $60 of respondents said that cryptocurrencies aid million for violating AML regulations. The agency in money laundering and only 9 percent feel attests that the owner violated the Bank Secrecy the cryptocurrency sector is doing enough to Act by operating an unregistered money service combat this. Cryptocurrency users appear to dis- business, marking the first time FinCEN has lev- agree, with only 56 percent of users expressing ied fines against a cryptocurrency site.

concern with money laundering and 48 percent AML COMPLIANCE IN OTHER saying that fraud is being sufficiently fought. INDUSTRIES World governments also widely distrust the Banks face various AML/KYC security and compliance standards of cryp- compliance challenges, studies find tocurrency exchanges. Eighty-nine percent of Challenges with AML/KYC compliance reg- government-employed experts surveyed said ulations are not confined to cryptocurrency that cryptocurrencies play a key role in dark web exchanges, with traditional FIs experiencing transactions, as opposed to 50 percent of users speed bumps as well. Forty-seven percent of who said the same. American banks in a recent study reported that

regulatory compliance is their primary challenge in 2020, with 40 percent of European banks reporting the same. The biggest reason cited for this struggle is that the workload for meeting AML/KYC compliance regulations is often distributed among multiple teams, which have It can take up to to do redundant work and effectively commu- nicate with one another when onboarding new customers. Experts say that all AML/KYC compliance duties should ideally be conducted by a single, dedicated team, but this is a pipe dream hours for many FIs. 25 Another perennial issue is the extended period to onboard a single of time it often takes to onboard customers. A second study found that it can take up to 25 high-risk entity. hours to onboard a single high-risk entity, in large part due to subpar data management practices. A third study reported that 81 percent of decision-makers at FIs said poor data management lengthens onboarding times and negatively

impacts customer experiences. could potentially reduce compliance risk, with 61 percent reporting that they had already seen Compliance professionals expect ML results in this field through the use of ML. These will play a crucial role in AML/KYC compliance ML applications are in place at several banks, with nearly two-thirds of FIs devoting up to $1 One way to potentially smooth over the frictions million to ML and 71 percent developing their associated with AML/KYC compliance is through own in-house applications. machine learning (ML) technology, according to a recent joint survey from Compliance Week, The top perceived benefit of ML applications Guidehouse and the International Compliance was improving KYC processes, according to 55 Association (ICA). Eighty percent of the 364 percent of respondents, with the technology compliance professionals surveyed said that ML enabling both faster decision-making and more

accurate risk assessments. ML programs take a AML/KYC compliance to cost financial significant amount of time to get off the ground, firms $42 billion in US and Canada in 2020 however, with the average application requiring New technologies and investments can make between six and 12 months to launch and modify compliance professionals’ lives much easier, to a bank’s particular needs and customer base. but they can also be extremely pricey. A recent study found that compliance at American and Experts predict automation, perpetual Canadian financial firms is expected to cost $42 KYC and other technologies to dominate billion this year, with the U.S. spending $35.2 AML/KYC field in the future billion and Canada spending $6.8 billion. This The AML/KYC field is continually evolving, both represents a 33 percent increase over spend- to introduce new technologies and to respond to ing in 2019, according to the report, but it is new techniques being deployed by money laun- still peanuts compared to financial crime com- derers. One trend industry experts expect to play pliance costs in Europe, which totaled $137 a larger role in the future is perpetual KYC, which billion last year. differs from traditional KYC in that it constantly This increase in compliance costs is due to monitors customer details rather than scan- both investments in new technologies and ning them once at onboarding or periodically added complexity resulting from the pandemic. every few years. This can provide much more Conducting AML and KYC procedures remotely current data about customer habits, potentially requires more time and effort to ensure that detecting signs of wrongdoing and providing electronically filed documents are correct and opportunities for personalization of new prod- legible. FIs are also handling a higher volume ucts or services. of smaller transactions rather than a smaller number of large transactions, leading to big- Another emerging trend is automation technol- ger costs eating away at roughly the same ogy that harnesses AI or ML to reduce some of amount of profit. the burden on human professionals. These sys- Nevada faces new urgency for AML/KYC tems will likely take advantage of large and open in cashless gambling data sets cobbled together by many different Casinos, cardrooms, racetracks and other compliance companies and regulators instead gambling establishments have long been asso- of solely relying on in-house data. This has the ciated with money laundering, and the growing potential to provide much more accurate AML popularity of online gambling has brought and KYC screening among all organizations this association to cyberspace. Several states using and contributing to this database. approved an expansion of online gambling in the

November election, encroaching on Nevada’s KYC compliance a prime issue for the Nevada traditional seat as the gambling capital of legislature to consider when it reconvenes in America. Customers are likely to turn to new February. Nevada approved a bill in June that online gambling operations in other states like imposes stricter regulations on AML/KYC com- Colorado, Nebraska and Virginia if they feel pliance for cashless transactions in the state, they are safer than Nevada’s operations, said but this new paradigm does not yet apply to Brendan Bussman, director of government gambling operations. affairs at Global Market Advisors, making AML/

Cracking Down On years, such as ethereum, monero and ripple, many of which leverage blockchain technology Cryptocurrency to serve as a transaction database.

Exchange Cybercrime These various cryptocurrencies are also With AML/KYC widely known for their roles in cybercrime, be it in their direct theft or in their use for laun- Compliance dering ill-gotten funds from other schemes. Cryptocurrency-related crimes totaled $4.3 bil- Cryptocurrency is one of the fastest-moving lion in 2019 — a larger sum than in 2017 and industries in the digital world, with a market 2018 combined. The same year saw $2.8 billion that was valued at $1.03 billion in 2019 and in laundered money flow through cryptocurrency is projected to reach $1.4 billion by 2024 at a exchanges, increasing from $1 billion in 2018. compound annual growth rate (CAGR) of 6.18 Government regulators and cryptocurrency percent. Bitcoin is one of the most famous exchanges are frantically looking for ways to reg- names in the cryptocurrency space, accounting ulate and prevent the laundering of stolen money for $6 billion in daily transactions among 153 through cryptocurrencies, with some methods million registered user addresses. The currency showing more promise than others. The fol- is well-known for its massive value fluctuations lowing Deep Dive explores how cybercriminals as a single bitcoin cost just 9 cents in 2010, leverage cryptocurrency exchanges for money $313.92 in 2015 and a staggering $13,421.44 laundering and how government agencies are in 2018 before sharply decreasing to $3,869.47 cracking down on exchanges that let launder- in 2019. Thousands of other cryptocurrencies ers run amok. began circulating on crypto exchanges in recent

How money launderers exploit activities take a variety of forms. Respondents cryptocurrency said they were most concerned about money Cryptocurrencies are popular for transactions laundering at 84 percent, followed by 79 percent in which users desire anonymity, such as when who were concerned about the use of cryptocur- purchasing illicit drugs or adult material, and it rencies to fund terrorist groups and 76 percent is this same anonymity that makes them pop- who were worried about their use in funding ular for money laundering. All transactions are human trafficking. There was a notable gulf in logged in to the blockchain, but these are typi- opinion when it came to perceptions of crypto- cally made under pseudonyms or usernames currencies’ risks, however: 63 percent of banks that are difficult to link to actual identities. This and 56 percent of governments felt cryptocur- lack of identity information is compounded by rencies posed a significant cybercrime risk as many cryptocurrency exchanges’ weak KYC opposed to only 9 percent of cryptocurrency procedures, with a recent study finding that 56 industry professionals. percent of all exchanges lacked sufficient KYC This gap in opinion means that any improve- processes, often on purpose to avoid comply- ment in cryptocurrency exchange AML/KYC ing with AML regulations. Most of these poorly procedures will likely come about through regu- protected exchanges are located in Russia, latory orders rather than reliance on exchanges the U.K. or the U.S., but some countries, like taking initiative. Seychelles and Singapore, lack KYC procedures on a large majority of their exchanges, mak- Enforcing AML/KYC compliance at ing them hotbeds for money laundering and cryptocurrency exchanges

other cybercrimes. World governments have already taken a number

Financial regulators, financial intelligence of steps to curb money laundering on crypto- units and many cryptocurrency exchanges are currency exchanges by requiring them to bring expressing growing concern about the increased their KYC processes in line with those of other use of cryptocurrencies for committing cyber- FIs. FinCEN announced in November 2019 that crimes. Seventy percent of respondents in a it would begin strictly enforcing the “travel rule” recent survey said that criminal activity was a for cryptocurrency exchanges. This rule forces top concern for professionals in the global cryp- exchanges to verify customers’ true identities tocurrency and financial industries, and such as well as identify any senders and recipients of cryptocurrency transfers worth $3,000 or more.

It was originally put into place in 2013 but was was forced to pay a $35,000 fine and was pro- only intermittently enforced over the next six hibited from ever running a money transmission years, letting many cryptocurrency exchanges service again, sending a firm warning to other continue their KYC-less practices with impunity. cryptocurrency exchanges about the conse- quences of failing to comply with AML and KYC The U.S. government worked to curb crypto- requirements. currency exchanges’ lax AML procedures in the same year, following the example set by other Cryptocurrency exchanges are therefore taking financial regulatory agencies around the world. their AML/KYC compliance more seriously and FinCEN charged the owner of a privately owned even partnering with third parties to help root out exchange with violating the Bank Secrecy Act by potential money launderers. Exchanges wishing failing to report more than 150 transactions that to provide a secure customer experience and were each worth more than $10,000 and thus avoid punishment from federal authorities would required a Currency Transaction Report to be do well to follow this example. sent to the Treasury. The owner of the exchange

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Trulioo, an identity verification solutions provider, aims to create products that can solve online identity verification challenges in ways that are accessible to both SMBs and large enterprise customers. The company offers a single portal/API that assists businesses with their AML/KYC identity verification requirements by providing secure access to more than 5 billion identities worldwide.

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