Crypto Platforms

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?

Thanks

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.

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.