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Cryptocurrency Exchange Investigations Flashcards

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  1. What is an address 'cluster' in the context of blockchain exchange investigations?

    Answer: A group of addresses identified as controlled by the same entity through heuristics like common-input ownership

    A cluster is a group of cryptocurrency addresses attributed to the same controlling entity, most commonly identified through common-input-ownership heuristics.

  2. When investigating a cryptocurrency exchange, which legal instrument prevents the exchange from alerting the customer that their records are being sought?

    Answer: Non-disclosure order (gag order) accompanying the subpoena

    A non-disclosure order (gag order) accompanying a subpoena legally prohibits the exchange from notifying the account holder that their records are under investigation.

  3. What is 'smurfing' in the context of cryptocurrency exchange investigations?

    Answer: Breaking large amounts into smaller transactions to stay below reporting thresholds

    Smurfing is a structuring technique that breaks large amounts into smaller transactions specifically to avoid triggering mandatory reporting thresholds like the $10,000 CTR.

  4. Which US government agency maintains primary AML/KYC regulatory authority over domestic cryptocurrency exchanges?

    Answer: FinCEN (Financial Crimes Enforcement Network)

    FinCEN, a bureau of the US Treasury Department, holds primary AML/KYC regulatory authority over cryptocurrency exchanges registered as MSBs in the United States.

  5. What is a Suspicious Activity Report (SAR) and who is required to file it?

    Answer: A confidential report filed by financial institutions including exchanges with FinCEN when suspicious activity is detected

    A SAR is a confidential report that financial institutions (including crypto exchanges) must file with FinCEN when transactions suggest potential money laundering or other criminal activity.

  6. An investigator receives exchange records showing a customer used a US driver's license but IP login records show consistent logins from a foreign country. What does this most likely indicate?

    Answer: Possible identity fraud, a synthetic identity, or a money mule account

    Consistent foreign IP logins despite US identity documentation suggests potential use of a fraudulent or synthetic identity, or that the account belongs to a money mule.