Although cryptocurrency can be used for illicit activity, the overall impact of bitcoin and other cryptocurrencies on money laundering and other crimes is sparse in comparison to cash transactions.
As of 2019, only $829 million in bitcoin has been spent on the dark web1 (a mere 0.5% of all bitcoin transactions.) Since blockchain technology provides a public record of each transaction, exposure to the risk of financial crime in cryptocurrency including bitcoin money laundering is manageable.
However, many MSBs remain unclear about their role in preventing money laundering and other crime on the blockchain, They may not know how to properly implement key AML processes such as Know Your Customer (KYC) identity verification or they may just feel like the challenges of unmasking criminals is a burden that’s not theirs to bear.
In these cases, MSBs May simply look the other way rather than confront the problem.
This is a mistake — and it can be a costly one.
While criminals will continue attempts to circumvent or exploit bitcoin’s blockchain, money laundering can be headed off at the pass with tools that match customer data with bitcoin transaction histories. This can make it easy for MSBs to identify high-risk customers, remain AML compliant, and avoid the taint associated with crypto money laundering.
How criminals use crypto to launder dirty money
Criminals use crypto money laundering to hide the illicit origin of funds, using a variety of methods. The most simplified form of bitcoin money laundering leans hard on the fact that transactions made in cryptocurrencies are pseudonymous.
The same concepts that apply to money laundering using cash apply to money laundering using cryptocurrencies. There are three main stages of crypto money laundering:
Cryptocurrencies can be purchased with cash (fiat) or other types of crypto (altcoin). Online cryptocurrency trading markets (exchanges) have varying levels of compliance with regulations regarding financial transactions.
Legitimate exchanges follow regulatory requirements for identity verification and sourcing of funds and are AML compliant. Other exchanges are not as AML compliant, not that they aren’t putting in the effort. It falls more to their ongoing struggle to exceed compliance regulations with sub-par tools. This vulnerability is where most transactions related to bitcoin money laundering take place. When exchanges are regulated, they are required to apply KYC policies and protocols to their customers. This allows for the matching of transaction data to the corresponding customer, thereby breaking the ‘anonymity’ for each transaction. At Elliptic, we don’t store customer data; instead, we use customer IDs (provided by exchanges) to match to transaction data.
Crypto-based transactions can generally be followed via the blockchain. However, once a dirty cryptocurrency is in play, criminals can use an anonymizing service to hide the funds’ source, breaking the links between bitcoin transactions. Often, the main excuse for illicit hiding activities is the argument that using anonymizing service providers protect personal privacy.
This can be accomplished both on regular crypto exchanges or by participating in an Initial Coin Offering (ICO), where using one type of coin to pay for another type, can obfuscate the digital currency’s origin.
The point at which you can no longer easily trace dirty currency back to criminal activity is the integration point — the final phase of currency laundering.
Despite the currency no longer being directly tied to crime, money launderers still need a way to explain how they came into possession of the currency. Integration is that explanation.
A simple method of legitimizing the illicit income is to present it as the result of a profitable venture or other currency appreciation. This can be very hard to disprove in a market when the value of any given altcoin can change by the second.
Alternately, similar to how an offshore fiat currency bank account can be used to launder dirty money, an online company that accepts bitcoin payments can be created to legitimize income and transform dirty cryptocurrency into clean, legal bitcoin.
Some of the most prominent cryptocurrency money laundering cases involve one or more of the following practices:
Mixing services, known as “tumblers,” can effectively split up the dirty cryptocurrency. Tumblers send it through a series of various addresses, then recombine it. The reassembly results in a new, “clean” total (less any service fees, which can often be substantial.)
In most laundering cases, the cryptocurrency starts in a legitimate wallet on the clearnet. It is transferred to a wallet in the dark web making multiple hops before landing in a second dark web wallet. It’s at this point that the currency is clean enough to bring back up to the clearnet and traded on a legitimate cryptocurrency exchange or sold for fiat.
Another avenue through which criminals can undertake bitcoin money laundering is unregulated cryptocurrency exchanges. Exchanges that are not compliant with AML practices and which fail to perform strict and thorough identity checks allow for cryptocurrencies to be traded over and over again across various markets, deposited onto unregulated exchanges, and traded for different altcoins.
The repeated exchanges of one type of cryptocurrency for another can slowly clean the bitcoin, which criminals can eventually withdraw to an external wallet.
In rare cases, they might convert cryptocurrency into cash, but this is atypical as fiat markets on unregulated exchanges are uncommon with only a brief tenure.
To lower bitcoin money laundering risk, many criminals turn to decentralized peer-to-peer networks which are frequently international. Here, they can often use unsuspecting third parties to send funds on their way to the next destination.
Most cryptocurrency money laundering schemes end with the clean bitcoin funneled into exchanges in countries with little or no AML regulations. It’s here that they can finally convert it into local fiat and use it to purchase luxury or other high-end items such as sports cars or upscale homes.
There were 5,457 bitcoin ATMs worldwide as of September 1, 20192. Continually connected to the internet, bitcoin ATMs allow anyone with a credit or debit card to purchase bitcoin. Additionally, they may possess bi-directional functionality allowing users to trade bitcoins for cash using a scannable wallet address. Bitcoin ATMs can also accept cash deposits, providing a QR code that can be scanned at a traditional exchange and used to withdraw bitcoin or other cryptocurrencies.
Regulations used by financial institutions to obtain a record of customers and transactions for these machines vary by country and are often poorly enforced. Criminals can exploit loopholes and weaknesses in cryptocurrency ATM management to get around bitcoin money laundering risks.
Prepaid debit cards loaded with cryptocurrency provide another avenue for bitcoin money laundering. Prepaid cards can be used to fund different types of illegal activities, traded for other currencies, or handed off along with associated PINs to third parties.
Gambling and gaming sites
Online gambling and gaming through sites that accept bitcoin or other cryptocurrencies is another way to conduct a crypto money-laundering scheme. Crypto can be used to buy credit or virtual chips which users can cash out again after just a few small transactions.
Elliptic AML allows users to configure risk rules based on personal appetites for risk. If you consider gaming high-risk, you can set your rules accordingly, and our tool will do the work for you. Elliptic AML monitors crypto transactions from addresses labeled as gaming sites, scores, & flags them alerting you with a rank based on your risk rule configuration.
Anti-money-laundering solutions for MSBs
MSBs committed to controlling money laundering will have to comply with legal frameworks in various countries implementing AML requirements. Compliance can help keep MSBs from becoming a front for cryptocurrency money laundering cases reducing bitcoin money laundering risk. Compliance can further cause criminals to shy away, keeping all transactions at the MSB free from the taint of dirty crypto.
Insisting on AML process, procedure, and systems centralization and compliance, however, can come with a potential downside: the loss of business with a large contingent of crypto users eschewing such rules and regulations.
The good news is centralization and compliance can easily offset any negativity with the added legitimacy earned by accepting restrictions and implementing AML requirements — such as identity verification for each transaction. Additionally, better risk management accompanies adherence to regulations that proactively help mitigate risk exposure.
Since hiding and obfuscating transactions are primary methods of cryptocurrency laundering, insisting on a clear record in the blockchain can further thwart money laundering attempts. When there is a clear unbroken trail of verifiable transactions, it becomes much harder to hide the origins of digital currencies.
US and global approaches to crypto
The United States has a muddled relationship with cryptocurrency. AML requirements for crypto to crypto transactions (as opposed to fiat to crypto or crypto to fiat transactions) have been inconsistent. There are also different thresholds for triggers regarding crypto as opposed to cash transactions.
Globally, AML enforcement, when it comes to cryptocurrency transactions, varies widely — from relatively strict regulations in the UK, Netherlands, and much of Europe to practically non-existent enforcement in other countries. In June, the Financial Action Task Force (FATF) issued a global requirement for cryptocurrency-related businesses to collect and share customer identities for each transaction, known as the Travel Rule.
The Travel Rule requires crypto exchanges to pass information about their customers to one another when transferring funds between firms. Member countries have one year to implement FATF guidelines (with a planned review set for June of next year).
The issuance was an effort by FATF to cut down on money laundering and funding of terrorist organizations.