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#2221410 - 09/11/19 06:11 PM Crypto Platforms
loyo111 Offline
100 Club
Joined: Mar 2006
Posts: 102
I have a few clients sending ACH transactions to platforms such as Coin Base and Robin Hood presumably for exchanging Crypto CCY.

If we cannot locate these platforms as registered MSBs in FinCEN's site, how are banks handling these transactions?

Do you not allow them altogether or do you monitor for ongoing patterns and escalate if the volume merits questioning?


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#2221420 - 09/11/19 06:42 PM Re: Crypto Platforms loyo111
ColoradoAML Online
Gold Star
Joined: Mar 2018
Posts: 277
We allow users but don't currently allow exchangers or administrators. If we saw activity that looked like someone was acting as an exchange, we'd exit the relationship. If we believed they were an exchange and weren't registered as an MSB, it sounds like a SAR would be warranted.

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#2221571 - 09/13/19 05:33 PM Re: Crypto Platforms loyo111
ACBbank Offline
Power Poster
Joined: Jul 2006
Posts: 4,156
New York City
Coinbase is registered with FinCEN as an MSB. I believe so is Robinhood Crypto. In terms of managing the relationships it would be dictated based on your AML Program/Policy.
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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