CoinList Markets LLC is a currency exchange. When its customers open accounts, there is a Know-Your-Customer (KYC) process which requires individual applicants to provide, among other things, their country of residence and address. CoinList maintained several sanctions compliance measures, including screening new and existing customers against Office of Foreign Assets Control (OFAC) and other sanctions lists. By spring of 2021, CoinList’s onboarding protocols also included an automated process through which an application was meant to…
Potentially in connection with the recent events rocking the crypto industry, FINRA is conducting a new sweep on “Crypto Asset Communications” by broker-dealers. If they haven’t already received the request, broker-dealers with crypto-related affiliates likely will be contacted. Notably, this is the first announced sweep that FINRA has issued in over a year. This Crypto Asset sweep is not limited to communications about crypto assets that are “securities,” and it requests recent crypto asset communications over a…
There has been talk over the past month about the possibility of the Trump administration issuing certain requirements relating to crypto-wallets. Just the rumors led to pushback. On November 25, 2020, for example, Coinbase CEO Brian Armstrong tweeted explanations of why he believed this was a bad idea and how the additional friction of such reporting requirements would kill many of the emerging use cases for crypto. He added, “Just like the U.S. benefited enormously…
On August 20, 2019, the Swiss Banking Association (“SBA”) released guidelines for member banks (in German with Italian, French and English versions to follow) about opening company accounts for companies with a nexus to distributed ledger technology (“DLT”). These guidelines update the SBA’s guidelines from September 21, 2018. The guidelines outline what banks should require of DLT-nexus companies in the account opening process to address risk management related to issues such as anti-money laundering (“AML”).…
On April 8, 2019, Jacob Burrell Campos of Rosarito, Mexico, was sentenced to two years in prison and to forfeit USD 823,357 in illicit profits for operating an unlicensed money transmitting business in connection with his sale of hundreds of thousands of dollars in Bitcoin to over 1,000 customers throughout the United States. Burrell, a U.S. citizen, pleaded guilty, admitting that he operated a Bitcoin exchange without registering with the Financial Crimes Enforcement Network (FinCEN)…