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#2148646 - 10/04/17 05:20 PM BITCOIN
JennKK2 Offline
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so just sharing with others who may have more exposure to this, but recently had two customers (they know each other & each have financial stability) wire money to Gemini Trust Company LLC. Having never heard of this company and two customers within days wire out, I researched to discover they are a bitcoin crypto currency exchange. I chose to place the customers on my high risk list as I have no baseline for this type of activity and want to be sure I'm aware of changes in the customers' accounts in relation to this new wire activity and if others in our community jump on board.

comments are appreciated
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#2148653 - 10/04/17 05:34 PM Re: BITCOIN JennKK2
RockChucker, CAMS Offline
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The Country
Thanks for sharing
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#2148677 - 10/04/17 06:30 PM Re: BITCOIN JennKK2
Daisy Doodle Offline
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We have run across Gemini Trust with two business customers. In both cases, they failed to honestly answer the MSB questions and we later closed both entities and filed SARS.

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#2148678 - 10/04/17 06:30 PM Re: BITCOIN JennKK2
Daisy Doodle Offline
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Forgot to say if you have an MSB keyword list, recommend you add this company if you have not already.

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#2148683 - 10/04/17 06:36 PM Re: BITCOIN JennKK2
JS913 Offline
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If you potentially want to add more high risk customers to your list, there are many exchanges but some of the other popular ones you might be on the lookout for include Coinbase, Kraken, and Cryptsy - you can fund via debit card or direct ACH once you verify your account. I've done keyword searches of our transaction data and have identified several customers using some of these exchanges, however, it seems most of them are one-off activities. There has a been a huge spike in news related to cryptos the last few months because the value has jumped so much which is why you might be seeing more customer's involved.

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#2148691 - 10/04/17 07:05 PM Re: BITCOIN JennKK2
Daisy Doodle Offline
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I don't worry about consumers buying virtual currency in reasonable amounts, absent any other factor. But undeclared MSB's just tick me off.

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#2148859 - 10/05/17 06:04 PM Re: BITCOIN JennKK2
JennKK2 Offline
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I have no automated AML system. There was mention of MSBs My two customers who wired money to Gemini are consumer customers. no MSB concerns. JS913 - i did read up on the "Coinbase, Kraken, and Cryptsy" so im aware of these terms. as far as keyword / exchanges i guess i could manually enter the key words into our ach files to search.
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#2149048 - 10/06/17 04:50 PM Re: BITCOIN JennKK2
Madawaska Offline
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Please confirm for me --

Can a business ever be termed a "User"? or does this term only apply to consumers.

Having an ongoing 'discussion' here on this subject. I recently discovered a crowdfunding customer account was opened that is in the business of investing in Ethereum. The argument is that they are only a User and don't need to be registered as an MSB. We also have a restriction in place for 'virtual currency administrators and exchangers' so they are trying to slip this by by saying they are only a "User".

Thanks

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#2149051 - 10/06/17 04:59 PM Re: BITCOIN JennKK2
BrianC Offline
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An exchanger purchases Bitcoin and behalf of third parties and then transmits the Bitcoin to other third parties based on the direction of its customer. A user is a person who buys and sells Bitcoin for themselves. There is no distinction between business and consumer for users. It is based on what is done with the Bitcoin.

Refer to FIN-2014-R001 in which FinCEN responds to some businesses that inquired about whether or not they were considered exchangers or administrators.
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#2149052 - 10/06/17 05:01 PM Re: BITCOIN BrianC
Elwood P. Dowd Offline
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If you and your customer do not have the same opinion, go with yours. wink
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#2149066 - 10/06/17 05:56 PM Re: BITCOIN JennKK2
Madawaska Offline
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Posts: 105
VA
Thanks for the response and information.

It is very helpful.

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