How Bitstamp Balances AML Efforts with Crypto Traders' Privacy Concerns

FEBRUARY 2021

FEATURE STORY NEWS & TRENDS DEEP DIVE How Bitstamp BitMEX announced How AML/ balances AML efforts verification of 100 KYC compliance with crypto traders’ percent of its users’ has evolved at privacy concerns (p. 10) identities (p. 14) cryptocurrency exchanges (p. 20)

WHAT’S INSIDE A look at recent AML/KYC developments, including why more than half of cryptocurrency exchanges have weak or no KYC protocols and the techniques they can deploy to improve their 04 compliance FEATURE STORY An interview with Caitlin Barnett, U.S. chief compliance officer at Bitstamp, on how the bitcoin exchange leverages user authentication and transaction analysis to fight money laundering while also respecting 10 legitimate users’ privacy concerns NEWS & TRENDS Recent headlines from the space, including BitMEX verifying 100 percent of its users’ identities and why a U.S. court recently sentenced a cryptocurrency exchange owner to 10 14 years in prison DEEP DIVE An in-depth examination of how AML/KYC compliance and regulations have changed in the cryptocurrency industry and why these exchanges are either stepping up their KYC game 20 or taking themselves out of it ABOUT Information about PYMNTS.com and 23 Trulioo

What’s Inside your customer (KYC) protocols, with one study even finding that 56 percent of exchanges Money laundering is a common scheme had weak KYC protocols or none at all. that authorities are constantly attempt- The good news is that cryptocurrency ex- ing to stamp out, with criminals processing changes are beginning to crack down on their profits to conceal their sources and money laundering on their platforms, both of law enforcement cracking down on the front their own volition and at the behest of fed- businesses that enable them. The United eral regulators. An especially game-changing States Treasury Department estimates that year for anti-money laundering (AML) and KYC $300 billion is laundered each year in the U.S. regulations in the cryptocurrency space was alone, with trillions more done internation- 2019, when federal agencies defined exchang- ally. This practice has become increasingly es as money service businesses, thus placing digital as eCommerce grows in popularity, them under the same AML/KYC purview as with cybercriminals setting up front busi- traditional financial institutions (FIs) under nesses online or leveraging digital currency the Bank Secrecy Act of 1970. Cryptocurrency exchanges to launder their money. exchanges are deploying a variety of tech- One attractive route for money laundering is niques to verify their customers and ensure through cryptocurrency exchanges, with cy- that illicit activities on their platforms are bercriminals exploiting their anonymous and detected and stopped, ranging from facial largely unregulated nature to convert dirty recognition scans via video onboarding to on- money into clean, untraceable funds. The MIT going transaction analysis that looks for signs Technology Review found that $2.8 billion in of money laundering when cryptocurrencies bitcoin was laundered through cryptocurren- change hands. cy exchanges in 2019 — up from $1 billion the The common conception of cryptocurrencies year prior. Many cryptocurrency exchanges as vehicles for dark web purchases may take are unwittingly turning a blind eye to these some time to dispel completely, but many cybercrimes with weak or nonexistent know exchanges are doing their best to remain

aboveboard. Cryptocurrency enthusiasts will been lacking in this regard. A recent survey have to hold exchanges accountable if they found that while 96 percent of cryptocurren- ever wish to see widespread adoption for cy users deploy multifactor authentication day-to-day purchases. (MFA), 25 percent do not back up their MFA codes, presenting a security risk. Half of sur- Around the AML and KYC world veyed users reported that they save their There have been a number of success stories online login credentials, which could also po- in AML/KYC compliance, including one from tentially be exploited if browser usernames cryptocurrency exchange BitMEX. The ex- were compromised. change recently announced that 100 percent Government regulators are cracking down on of its users’ identities have been authenticat- cryptocurrency exchanges that do not have ed following an initiative that began in August their AML/KYC houses in order. A U.S. court 2020, after the U.S. Commodity Futures recently sentenced the owner of exchange RG Trading Commission charged the exchange Coins to 10 years in prison for money launder- for its illegal operation of a derivatives trading, finding that the owner aided fraudsters ing desk. BitMEX revamped its AML and trade in an auction scam selling goods that did not surveillance systems in November, and user exist and exchanged victims’ money for cryp- verification for deposits, withdrawals and tocurrencies to hide its source. Prosecutors trades became mandatory in December. stated that RG Coins laundered nearly $5 Part of secure cryptocurrency trading in- million in cryptocurrency in this fashion, with volves users taking their personal security RG Coins’ owner receiving a cut of more than into their own hands, but many users have $184,000.

EXECUTIVE INSIGHT

For more on these stories and other AML and KYC developments, read the Tracker’s News and Trends section (p. 14). One of the main draws of cryptocurrency is its anonymous nature and a lack of oversight. How Bitstamp balances AML protocols with privacy concerns How can exchanges implement secure KYC protocols without alienating this userbase? Cryptocurrency exchanges have started tak- “Taking a holistic, layered approach is key for ing AML/KYC seriously in the past few years cryptocurrency exchanges [looking] to imple- due to the expanding threat of money laun- ment secure and appropriate KYC processes dering as well as new federal regulations. without ruining the customer experience. This New AML/KYC protocols often result in allows them to assess operational and business risks, understand the nuances of unique friction with long-standing legitimate cryp- market demographics, keep abreast of KYC, tocurrency users, however, who feel these AML and other compliance requirements new systems infringe on their privacy. In this across various jurisdictions, and simply un- month’s Feature Story (p. 10), PYMNTS spoke derstand if the right data is being collected with Caitlin Barnett, U.S. chief compliance at the right time. officer at Bitstamp, about how the bitcoin Applying a holistic approach will also ensure exchange balances secure AML protocols that legitimate users experience the appro- with seamless user experiences. priate customer journey while bad actors are stopped. Overall, there need to be safeguards Deep Dive: How cryptocurrency exchanges wherever individuals transact online to pre- have reacted to AML/KYC regulation changes vent fraud or the circumvention of AML/CFT regulations. Cryptocurrency has become exceedingly pop- Verifying and authenticating users with a va- ular as a driver of online transactions and a riety of identity verification protocols built volatile — yet often profitable — investment. from a risk-based approach is key and, in the It has also been a honey pot for money laun- long run, will work to build trust, loyalty and derers due to its anonymous nature, however, ensure that users are transacting safely. forcing regulatory bodies and the cryptocur- The benefits of alternative finance and dig- rency industry to develop ways to keep illicit ital assets should not have to conflict with activity out of exchanges. This month’s Deep existing standards and protections. In fact, Dive (p. 20) explores how AML/KYC regula- regulations will work to further legitimize crypto in the mainstream and safeguard tions have evolved over time and the various legitimate, good actors while stopping nefar- measures exchanges have instituted to pre- ious activities.” vent money laundering.

ZAC COHEN Chief operating officer Trulioo

REGULATION

Congress has instituted new cryptocurrency money laundering regulations as part of a new defense bill.

VERIFICATION

BitMEX reported that 100 percent of its users have now been verified.

CRACKDOWN

CoinDCX froze four major accounts on money laundering suspicions.

200%

Growth in the number of cryptocurrency exchange customers onboarded since 2018

719%

Growth in cryptocurrency transaction volume since August 2020

AML/KYC

Account ECOSYSTEM opening/tx processing

CONSUMER BUSINESS

• Name • Business name • Address • Address KYC/KYB • Phone Number • Phone Number • Registration number • Government-issued ID • Beneficial owner • Date of incorporation

• Government-issued ID • Government registry • Mobile carrier data • International Verification • Public records AML watchlist • Other sources • Public records

Risk assessment Identified as engine low risk

Identified as Conduct enhanced No further high risk due diligence (EDD) review needed

NO YES

Person/business is Person/business is downgraded to low-risk demarketed

How Bitstamp Balances AML procedures to slow the movement of these Efforts With Crypto funds. Cryptocurrency’s very nature even Traders’ Privacy makes these initiatives a breeze in some cases, according to Caitlin Barnett, U.S. chief Concerns compliance officer at Luxembourg-based bitcoin exchange Bitstamp. Cryptocurrency has become incredibly pop- “Historically, cryptocurrency has gotten a ular in recent years, from bitcoin’s founding bad rap because when people first heard in 2008 to its achieving wide acceptance on of it, it was synonymous with its use on the many online marketplaces. Bitcoin is cur- dark market and being used for illicit activ- rently valued at $32,200 as of January 2021, ities,” she said. “But what is coming to light with some experts predicting it could hit more recently — but obviously still needs to an all-time high of $55,000 per coin by the become more mainstream — is that it’s actu- end of the year. It may be the better-known ally way easier to trace cryptocurrency than household name, but there are thousands it is to trace fiat currency. There are a num- of different cryptocurrencies in circulation ber of blockchain analytics providers that for potential investors to trade and transact most cryptocurrency companies utilize to with, such as Ethereum, Ripple and Monero. essentially follow the money when it comes This also means that money launderers have to crypto.” boundless opportunities to make off with Barnett detailed in a recent interview with ill-gotten gains. Billions of dollars in illicit PYMNTS how Bitstamp works to verify its us- funds flow through cryptocurrency exchang- ers’ identities and trace these transactions es each year to exploit the anonymous nature to ensure they are not being used for money of such transactions, but exchanges — ei- laundering, offering a snapshot of the threats ther of their own volition or at the urging of and challenges facing the industry’s future. government regulators — have taken sig- nificant steps to implement AML and KYC

How Bitstamp fights money launderers

Bitstamp divides its AML/KYC procedures into two distinct halves: user authentication at the point of onboarding and transaction I do think what the analysis that looks for ongoing signs of money laundering among current users. The user crypto industry has verification protocol leverages a number of different data points to ensure that users are done a really good job who they say they are and have not previ- ously been involved in any criminal activities, of is explaining why according to Barnett. “We’re collecting photo IDs, names, address- we are requesting es, dates of birth, Social Security numbers and screening against sanctions lists, neg- [KYC] information ative media lists, et cetera to ensure that our customers are not known to be in- from our customers, volved in illicit activity,” she said. “We utilize a third-party vendor to help with our identi- so at least they know ty documentation verification. We’ll also do a live video and require the customer to say that we’re not just specific numbers or words. That’s reviewed to ensure that the person that’s onboarding collecting it for the is actually the person behind the ID.” sake of collecting it. A customer could easily pass an onboarding check in good faith and later turn to money laundering, however, making it critical that firms continue to examine transactions after the onboarding stage. There are a variety of The blockchain structure that bitcoin and signs that money laundering could be taking many other cryptocurrencies utilize pro- place, too. vides exchanges like Bitstamp an edge in this “If you see high dollar amounts coming in and analysis, according to Barnett. The block- you’re unable get the customer to explain the chain keeps a far more accurate transaction source of [the] funds, that would be a red flag history than can be provided by fiat curren- that we would probably investigate a little bit cy, enabling Bitstamp’s analysts to quickly further and potentially file suspicious activity ascertain if it has been in the hands of any reports,” she said. suspicious sources.

“On the blockchain analytics side, you can respective regulatory regimes. I do think what see where the funds are coming from — [and] the crypto industry has done a really good job are going to — both indirectly and directly,” of is explaining why we are requesting that she explained. “So we have clear sight as to information from our customers, so at least whether or not the funds are coming or go- they know that we’re not just collecting it for ing from a dark [web] market, for example. the sake of collecting it.” Other times, it might not be directly from [a AML professionals must also constant- dark web market], but the customer may be ly keep up with fraudsters’ latest strategies. trying to obfuscate the source of funds, and Every successfully blocked money launder- based on recognition of those patterns, we ing stratagem is immediately replaced with a can identify that there is potentially illicit ac- new one, forcing fraud-fighting teams to an- tivity going on.” ticipate threats before they occur. These techniques can go a long way toward “The fraudsters out there are really sophisti- preventing money laundering at Bitstamp cated, and anytime you figure out how to put and other exchanges. Fraudsters, howev- a control in place, their next job is to figure er, like the security experts themselves, are out how to get … around it,” Barnett said. “I constantly innovating, and users’ security ex- describe it as whack-a-mole, where you hit pectations are changing as well. all the moles, and then they’re quiet for a little bit, and then something else pops back Future challenges from both fraudsters and legitimate users up. So it becomes about staying on your toes and watching for industry trends.” One of the biggest challenges that exchanges User authentication and transaction analysis like Bitstamp face in their AML/KYC efforts may be the name of the game now, but new is resistance not from fraudsters but from money laundering techniques could easily legitimate cryptocurrency exchange users make these systems irrelevant. AML/KYC de- who value their anonymity. Exchanges must velopers will have to keep their fingers on the perform a constant balancing act of fight- pulse of new trends and proactively develop ing fraud while also respecting users’ privacy countermeasures if they want to keep money concerns. launderers off their platforms. “[Original] bitcoin believers are really hesitant to provide any [KYC] information,” Barnett said. “They like the thought of having cryp- to be anonymous, but there are certain things that we are mandated to collect under our

Taking action against subpar government-owned and does not employ more than 20 people or have $5 million in AML/KYC gross receipts, meaning that the bill is spe- compliance cifically targeted at smaller businesses and holding companies. All owners of nonex- Congress passes anti-money laundering act empt companies must have several data as part of defense bill points of identity logged in FinCEN’s data- AML/KYC compliance is something the U.S. base, including name, address and driver’s government takes seriously, as failing to ef- license number. fectively stop money launderers can result in massive windfalls for organized crime Indian cryptocurrency exchange freezes suspicious accounts amid bitcoin surge rings, terrorist groups and human traffickers. Congress recently took steps to curb money India lacks any sort of federal oversight for laundering with the Anti-Money Laundering AML/KYC compliance at cryptocurrency Act of 2020 (AMLA), which was passed as exchanges, leaving exchanges to take secu- part of the National Defense Authorization rity into their own hands. One of the largest Act for Fiscal Year 2021 omnibus bill. AMLA cryptocurrency exchanges in the country, bans the use of anonymous shell companies CoinDCX, recently froze four of its major by requiring disclosure of all beneficial own- accounts on suspicion that prices of small- ers in order to gain a more holistic view of er cryptocurrencies were being artificially how companies make and distribute funds. inflated. The exchange alleges that these accounts intended to lure retail investors to Owners of reporting companies will be buy these cryptocurrencies at inflated pric- logged in the Financial Crimes Enforcement es, which could potentially constitute fraud. Network’s (FinCEN) nonpublic beneficial ownership database. The act defines a re- These freezes occur as bitcoin, one of the porting company as any organization that most valuable and popular cryptocurrencies, is not a financial institution (FI), is not recently hit a value of $40,000. The growing

cryptocurrency market has inspired many initiative began in August 2020 after BitMEX government regulators around the world to came under fire for its lax KYC policies, take action to further monitor the AML/KYC with the U.S. Commodity Futures Trading standards at these exchanges, with FinCEN Commission charging the exchange for illegal recently proposing mandatory KYC standards operation of a derivatives trading desk. for cryptocurrency transfers in excess of The initiative was in full swing by November, $3,000, for example. with a revamp of the exchange’s AML and trade surveillance systems; user verification BitMEX reports 100 percent certified customer base following user verification for deposits, withdrawals and trades became program mandatory in December. BitMEX said that verified users have traded more than $100 Cryptocurrency exchanges can be notorious billion on its platform since the completion of for their weak AML/KYC compliance ef- its user verification program. This could sig- forts, but there are still success stories to nal to other exchanges that user verification be found. One example is controversial plat- is not necessarily damaging to bottom lines form BitMEX, which recently announced the but instead could help such platforms thrive. completion of its user verification program resulting in 100 percent of its users’ identities being authenticated and confirmed. This

Security threats facing cryptocurrencies 96% of Many cryptocurrency users do not deploy security best practices, survey finds cryptocurrency Security is paramount for any financial asset, especially cryptocurrency, which exists users only in cyberspace and can potentially be pil- fered by a hacker thousands of miles away. deploy multifactor A substantial portion of cryptocurrency users do not account for their own security as well authentication, but as they think they do, according to a recent survey. Ninety-six percent of asset hold- ers deploy multifactor authentication, but 25% do not back up 25 percent do not back up their MFA codes, creating a security risk. Half of surveyed us- their MFA codes. ers save their login credentials online, which fraudsters could exploit if they got ahold of the information. Two-thirds of respondents used a hardware wallet — a physical item that can keep cryp- exchanges are actively giving launderers a tocurrency offline and away from digital fraud hand in exchange for profit. A U.S. court re- — but 67 percent of these hardware wallet cently sentenced the owner of exchange RG users have a backup paper wallet, which con- Coins to 10 years in prison for money laun- sists of a printed code that they can scan to dering, finding that he deliberately aided access their cryptocurrency. More than half fraudsters in laundering their ill-gotten gains of these paper wallet users admitted that and shielded them from criminal liability. The their private security keys could be compro- fraudsters deployed an auction scam to sell mised if a fraudster were to find this paper. goods that did not exist, quickly exchanging victims’ money for cryptocurrencies via RG Cryptocurrency exchange owner sentenced to 10 years in prison for money laundering Coins to hide its source. Prosecutors said that RG coins laundered al- Many cryptocurrency exchanges are tak- most $5 million in cryptocurrency from the ing bold steps to limit the spread of money fraud ring Alexandria Online Auction Fraud laundering on their platforms, while some

(AOAF), with RG Coins’ owner getting a cut can still be subject to compliance regulations of more than $184,000. The owner was found if they decide which tokens to add to their guilty under the Racketeer Influenced and platforms. Fully decentralized exchanges also Corrupt Organizations Act (RICO), and 17 AOAF often result in reduced profits for owners, members were convicted of similar crimes. further disincentivizing this decision.

Bitstamp implements stricter KYC protocols New AML/KYC for Dutch users Not all KYC protocols are created equal, with implementations cryptocurrency exchanges and other financial ShapeShift integrates decentralized organizations deploying extra scrutiny to- exchange protocols to avoid KYC regulations ward certain users. Cryptocurrency exchange Bitstamp recently announced that it would Decentralization is one of the key draws for implement stricter KYC protocols for users many cryptocurrency fans, as it means hav- in the Netherlands due to new regulations ing the currency’s value determined by the from De Nederlandsche Bank, the country’s market rather than a central authority or central FI. Dutch users are no longer allowed government agency. One cryptocurrency to withdraw funds directly to third parties exchange, ShapeShift, is taking a similar ap- and are instead required to move crypto- proach to KYC by implementing almost a currencies to their individual wallets first, dozen decentralized exchange (DEX) proto- after which they can transfer funds wherever cols. This will result in customers not having they desire. to go through KYC protocols, yet it purports to heighten security nonetheless. The im- Bitstamp also added whitelisting to every plementation of DEX protocols means that Dutch user account, requiring them to man- ShapeShift is no longer custodian, counter- ually add cryptocurrency addresses to their party or intermediary to any cryptocurrency whitelist before they are allowed to send trades, according to CEO Erik Voorhees, but funds to them. Other cryptocurrency ex- will instead be classified as a software tech- changes, not wanting to comply with these nology company and will not be subject to new rules, have left the Netherlands entirely, KYC regulations. including cryptocurrency derivatives provider Deribit. Some experts believe that DEX protocols do not fully result in KYC or AML removal and that decentralization instead works more on a spectrum. Most DEX protocols still have AML/KYC procedures in place, according to John Todaro, director of research at digital currency software developer TradeBlock, and

Why AML/KYC Regulations Left AML/KYC procedures that keep money laun- Cryptocurrency derers away from more established financial institutions, with a recent study finding that Exchanges With A 56 percent of all exchanges had weak or no KYC processes at all. Laundered funds can Difficult Choice go toward any number of nefarious purposes, such as drug or human trafficking, tax eva- Decentralized finance (DeFi) is currently one sion or even terrorist financing. of the most dynamic trends in the financial Governments are cracking down on these space, with more than 5,000 different cryp- exchanges to curb cybercrime, and the ex- tocurrencies in circulation as of June 2020 changes themselves are taking a variety of and the market expected to hit $1.7 billion measures to ensure AML/KYC compliance. by 2027. It is also notoriously volatile, how- The following Deep Dive explores how AML/ ever, with bitcoin dropping from $19,783 in KYC compliance and regulations have evolved December 2017 to $3,400 in 2018, then go- in the cryptocurrency industry and how ex- ing back up to $20,000 as of December 2020, changes have reacted to these changes by for example. Ethereum experienced simi- either stepping up their KYC game or bowing lar shifts, decreasing from $1,300 to $91 over out altogether. the course of 2018 and rising to $450 by the end of last year. These dramatic fluctuations, How AML/KYC has changed over the course paired with its propensity for confidentiality of crypto history and lack of regulation, make cryptocurrency Anti-money laundering efforts are as old as attractive for thrill-seeking investors. money laundering itself, with authorities con- These same factors also make it an appealing stantly seeking ways to cut off funding for target for money launderers, however: 2019 criminal organizations and limit the reach and saw $2.8 billion laundered through crypto- effectiveness of their schemes. Most modern currency exchanges — up from $1 billion the efforts to combat money laundering in the year prior. These exchanges largely lack the U.S. stem from the Bank Secrecy Act of 1970,

which required banks to actively cooper- counterparts. Most KYC checks are done af- ate with federal authorities in detecting and ter the fact, for example, instead of during reporting money laundering. This was fol- onboarding, as in most traditional banks. This lowed by the Money Laundering Control Act means that while many exchanges require of 1986 and the Anti-Drug Abuse Act of 1988, an uploaded ID document and a photograph, but KYC did not fully enter the picture until users are permitted to begin trading immedi- the Patriot Act of 2001. Part of this contro- ately and are stopped only if the KYC check versial legislation aimed to stem the flow of brings up something suspicious, rather than funds to terrorist organizations by requiring having to wait for it to clear before transact- FIs and other money handlers to thoroughly ing. Other cryptocurrency exchanges allow vet their customers and partners under pen- users to open accounts without any KYC alty of law. check at all, instead severely limiting their AML and KYC regulations have only started transaction privileges, such as by disallowing affecting the cryptocurrency industry in the withdrawals, until a check is completed. past few years, and the space is still large- Some cryptocurrency exchanges have de- ly unregulated. It was not until 2019 that cided to stop doing business with U.S. FinCEN, the Commodity Futures Trading customers rather than institute even rudi- Commission (CFTC) and the Securities and mentary KYC and AML procedures. One of the Exchange Commission (SEC) issued a joint largest exchanges in the country, Poloniex, statement that defined cryptocurrency - ex announced in 2019 that it would no longer ac- changes as money service businesses (MSBs), cept American users on its platform following thus making them subject to AML and KYC FinCEN’s placement of exchanges under regulations under the Bank Secrecy Act. This the jurisdiction of the Bank Secrecy Act. was followed by new regulations for crypto- Cryptocurrency enthusiasts worry that these currency wallets and cryptocurrency holdings new AML and KYC regulations will undermine at foreign exchanges. The U.S. cryptocurren- the anonymous nature that made cryptocur- cy industry now faces a hard choice: Start rencies so enticing in the first place, but the fresh with new KYC and AML regulations and government argues that regulations are nec- potentially alienate customers used to an essary to keep terrorists and cybercriminals unregulated market or remove their business from funding their operations. from the U.S. entirely and potentially lose This ongoing debate will certainly not be set- domestic customers. tled anytime soon. What is certain, however, is that cryptocurrency exchanges that wish How the cryptocurrency industry reacted to evolving regulation changes to remain in the U.S. will need to drastically improve their AML/KYC procedures or risk a KYC is still quite new to the cryptocurren- knock on their virtual doors from Uncle Sam. cy world, and exchanges often deploy it differently compared to their traditional FI

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PYMNTS.com is where the best minds and the best content meet on the web to learn about “What’s Next” in payments and commerce. Our interactive platform is reinventing the way in which companies in payments share relevant information about the initiatives that shape the future of this dynamic sector and make news. Our data and analytics team includes economists, data scientists and industry analysts who work with companies to measure and quantify the innovation that is at the cutting edge of this new world.

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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