elliptic-防止加密资产中的金融犯罪：针对合规专业人士的权威实践指南（英）-138页_10mb

Summary of Preventing Financial Crime in Cryptoassets (2022 Edition)

Core Content

This report provides a comprehensive guide for governance, risk, and compliance professionals to understand and mitigate financial crime risks in the cryptoasset space. It outlines the evolving nature of money laundering, terrorist financing, and other illicit activities, emphasizing the need for proactive and practical compliance measures.

Main Points

The Growth of the Cryptoasset Space

• The cryptoasset market has grown rapidly since 2018, driven by innovations such as DeFi, NFTs, and stablecoins.
• These innovations are enabling new forms of financial crime and are contributing to the development of the "metaverse."
• Traditional financial institutions are increasingly entering the crypto space, which has created a more complex regulatory environment.

Key Financial Crime Risks

• Money laundering and fraud & scams are the top financial crime risks identified by respondents.
• Sanctions evasion and terrorist financing are also significant concerns, especially following the Russian invasion of Ukraine in 2022.
• DeFi is the most cited innovation with high financial crime risk, due to its decentralized nature and lack of KYC/AML controls.

Survey Insights

• Over half of the respondents use blockchain analytics tools to detect financial crime.
• A 50/50 split exists in confidence levels regarding the ability to detect crypto-related financial crime accurately.
• The report serves as a desk guide to complement Elliptic's blockchain analytics tools for compliance teams.

Key Financial Crime Typologies

Part I: Money Laundering

• Cryptoasset Exchanges: Non-compliant or unlicensed exchanges are a major risk, as they allow criminals to move illicit funds with minimal oversight.
• Peer-to-Peer (P2P) Platforms: These can be used to launder funds through informal channels.
• Decentralized Finance (DeFi): Risks include the use of DEXs, mixers, and cross-chain bridges.
• Cryptoasset ATMs: Used to facilitate illicit transfers and money mule activities.
• Gambling and Gaming Services: Criminals may use these platforms to clean illicit funds.
• Prepaid Cards: Used to layer and integrate illicit proceeds.
• Mixers and Privacy Wallets: Enable anonymization of transactions.
• Tokens and Stablecoins: Facilitate laundering of proceeds from scams and hacks.
• NFTs: Can be used for money laundering, fraud, and theft.
• Wallet-specific Behaviors: Such as chain peeling and multi-customer cross-wallet activity.
• Banks and Indirect Exposure: Banks may be indirectly exposed through VASP transactions or correspondent relationships.
• Privacy Coins and Chain Hopping: Used to obscure the origin and movement of illicit funds.
• Multi-technique and Multi-service Typologies: Criminals often combine multiple methods and services to evade detection.

Part II: Terrorist Financing

• Crowdfunding through Charities: Used to fund terrorist activities.
• Individuals or Small Cells: Engage in illicit transactions using cryptoassets.

Part III: Key Trends: Criminals and Threat Actors

• Hackers and Cybercriminals: Use cryptoassets for ransomware and other cybercrimes.
• Dark Web Vendors: Facilitate illicit transactions and money laundering.
• Fraudsters: Exploit cryptoassets for scams and phishing.
• Professional Money Launderers: Use sophisticated methods to obscure illicit funds.
• Street Drug Dealers: Use cryptoassets for transactions and money laundering.
• Human Traffickers and Sex Trade Perpetrators: Leverage crypto for anonymity and cross-border transactions.
• Tax Evaders: Use cryptoassets to hide income and evade taxes.
• State Actors and Sanctions Evaders: Exploit crypto for bypassing sanctions.
• Terrorists and Political Extremists: Use cryptoassets to fund operations and evade detection.

Case Studies and Examples

• SUEX and Chatex: These unlicensed exchanges were key facilitators of ransomware proceeds, with OFAC imposing sanctions due to their involvement in laundering large sums.
• BTC-e: A notorious exchange that operated in high-risk jurisdictions and facilitated various crimes, including ransomware and fraud. It was eventually shut down and subject to a $110 million fine by FinCEN.

Red Flags and Warning Signals

• Unlicensed or non-compliant exchanges: No KYC/CDD requirements, unclear AML policies, and association with criminal activity.
• High-risk jurisdictions: Exchanges registered in sanctioned or non-cooperative countries, with unclear ownership or operations.
• Anonymity and privacy tools: Use of mixers, privacy coins, and wallets that obscure transaction trails.
• Unusual transaction patterns: Chain peeling, multi-customer cross-wallet activity, and illicit transfers via ATMs or gambling platforms.

Key Controls

• Blockchain analytics tools: Used to detect and monitor illicit activity.
• AML/CTF governance systems: Necessary for identifying and mitigating risks.
• Address clustering and flow tracking: Helps in tracing the movement of funds.
• Monitoring of dark web and ransomware activity: Essential for identifying and responding to threats.

Conclusion

The report underscores the critical need for compliance professionals to stay informed about the evolving financial crime landscape in cryptoassets. It highlights the importance of using advanced blockchain analytics and implementing robust AML/CTF controls to address the risks posed by the convergence of traditional finance and crypto. Elliptic emphasizes its role in providing tools and insights to help the industry combat these challenges effectively.