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About three years ago, a so-called crypto-anarchist, deep into libertarianism, hired me to write a book that included content railing against government anti-money laundering regulations. As he saw it, there is essentially nothing wrong with financially supporting terrorist organizations, smuggling drugs or other contraband items. (Hell, there was nothing wrong with terrorism to him; one man’s terrorist is another man’s freedom fighter). People can do what they want as long as they don’t harm others. Drugs and prostitutes (for instance) delight individuals. And, therefore, the government, which, by the way, does a lousy job of literally minding its own business should focus on “minding its own business”.
Five years later and knowing more on money laundering, I think large-scale smuggling and certainly funding terrorists may have more negative social and economic ramifications than my well-meaning friend opined. This is partly because unrequited criminal laundering turns us into a criminal society – after all why work ethically when we can make far more money in illicit activities. Above all, successful money laundering means more drugs on the streets, more drug-related crime, more fraud, more corporate embezzling, and more terrorism, among a host of other social ills.
What is money laundering?
Money laundering, at its simplest, is the act of trying to make money that comes from nefarious Source A look like it comes from “clean” Source B. If caught, the perpetrator can’t use that money, since law enforcement would seize it. Source A involves funding ISIS, smuggling cocaine, engaging in corrupt political businesses, or benefiting from fraudulent business schemes, as examples.
If I were involved in any of these activities and would want to retain my stash, I’d be advised to go through the following three steps:
- Placement – Find a place to stash my money. If I wire the trove to my banks Capital One or Charles Schwab, they’d have to tell the government I’m suddenly depositing millions in checks. So I need to find a resilient hiding place.
- Layering – Money launderers can teach me all sort of schemes like wiring money between different accounts in different names in different countries, or purchasing high-value items (boats, houses, cars, diamonds) to change the form of my money. I can also change my money’s currency – and this is where cryptocurrency comes in. So, I can change my dirty dollars into Bitcoin and then again into Monero or Dash to better hide its source – now there’s a way to evade the cops!
- Integration – At this point, my money re-enters mainstream society as though it comes from a legitimate source. I’ve strategized in such a way that my startling fortune is innocuous and can slip under the radar.
The government’s response to money-laundering
In the United States, the Department of Justice, the State Department, the Federal Bureau of Investigation, the Internal Revenue Service and the Drug Enforcement Agency join forces in catching money-launderers like me. State and local police investigate cases under their jurisdiction. On the international stage (and when it comes to blockchain), organizations like the United Nations, the World Bank, the International Monetary Fund and the Financial Action Task Force on Money Laundering (FATF) send in their troops. The last has 33 member states and organizations, as of 2018.
Cops combine legislation with law enforcement. In the United States, legislative acts include:
- The Bank Secrecy Act (1970) – Financial institutions have to report all single transactions above $10,000 and multiple transactions totaling more than $10,000 to or from a single account in one day. When it comes to the blockchain industry, this includes money service businesses (MSB), too. Bankers who violate this rule can serve up to 10 years in prison.
- The 1986 Money Laundering Control Act – Any aspect of money laundering is a crime punishable by fines or jail.
- The 1994 Money Laundering Suppression Act – Banks have to establish their own money-laundering task forces to weed out suspicious activity in their institutions. When it comes to blockchain-based financial institutions, customer due diligence (CDD) rules are no different.
In truth, it’s a perpetual chase of cops vs. robbers, with the robbers mostly slipping through even as cops set the traps.
How do AML rules impact ICOs?
ICOs, also known as token sales, can fall foul of anti-money laundering regulations with their digital tokens. While “utility tokens” that only give investors access to the startup’s features are ok, it is the “security tokens” that may offer investors equity or some form of an investment return that are problematic.
This is where a growing number of ICOs interest themselves in Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations for reasons that include the following:
- Establish credibility with banks – After all, banks don’t want to trip up with organizations like FinCen, a bureau of the U.S. Department of the Treasury, that snoops into whether financial institutions are adhering to KYC.
- Long-term legitimacy – It’s good for your bottom line. You don’t want the government to bust your booty as happened in 2014 with Mt. Gox, the largest Bitcoin exchange, after the US Department of Homeland Security (DHS) seized suspicious money from its U.S. subsidiary account.
- Improved public perception – You appear more legitimate. You’re more likely to interest investors. The Dutch Authority for the Financial Markets (AFM), for one, warns consumers to avoid ICOs:
“Due to their unregulated status and the anonymous nature of the transactions involved, ICOs are attractive for the laundering of money obtained by criminal means. .. Because of these risks, there is a strong possibility that investors will lose their entire investment.”
With your compliance to KYC/ AML rules, you prove the AFM wrong.
4. Expanded reach – You’re more likely to attract investors in countries with rigid KYC/AML regulations like US, UK and Canada.
5. Avoid Regulatory Fines – There have been cases of regulatory bodies fining or suffocating ICOs that smell suspicious. With the Mt. Gox case, more than 3,000 customers lost some, or all, of their investments. You really don’t want that happening to you! AML in practice?
Our most recent guide to all there’s to “KYC: A Practical Guide for Blockchain Entrepreneur and Investor” gives you the overall picture.
Really, it reduces to three steps:
- Identify and do background checks on depositors.
- Report all suspicious activity. (For example, if a background check revealed that depositor A works in an oil rig, and he deposits $2,000 every two weeks, a series of ten $9,000 deposits over two weeks should worry you.)
- Build an internal task-force to identify laundering clues.
The rest is up to you.
Headquartered in Kiev, Liqui is a crypto-only cryptocurrency exchange with a 235 trading pairs. Liqui offers both a public and private API for programmatic trading and states a 24-hour volume of around 1250 BTC. Liqui’s numerous trading pairs are all against its three main currencies, BTC, ETH, and USDT, meaning that those looking to trade with fiat will want to find a different exchange or a method of converting their crypto after the fact. Overall, It is a good choice for small to medium traders, especially those looking for the ability to trade programmatically against a large number of cryptocurrencies.
Liqui finds itself at #23 on BlockExplorer’s list of the top 25 cryptocurrency exchanges of 2017.
Trading pairs: 235
Deposit Fees: No
Withdrawal Fees: No
Trading fees: Yes
Margin Trading: No (coming soon)
Fees and Limits
Liqui lays out its fees in the usual maker/taker scheme, where makers pay a 0.10% fee and takers pay a 0.25% fee. All of Liqui’s trading pairs currently have the same fees applied to them. Fees are listed on Liqui’s Fees and Limits page, with the fees specifically only listed for the three ‘main’ cryptocurrencies you trade against; Bitcoin, Ethereum, and USD Tether.
Limit-wise, Liqui has three levels; New accounts are split into three 24 hour periods, where their withdrawal limit increases by 5,000 USDT or equivalent per day, starting at 5,000 USDT. Following the new account restrictions, an account receives the “Basic Account” withdrawal limits of 50,000 USDT or equivalent per day. And lastly, for “Enhanced Accounts”, the limit is 500,000 USDT or equivalent per day. Note that the Enhanced Account’s limit requires both verification and 2FA to be enabled on the account.
Registering an account on Liqui is simple, and requires a username, email, and password. A confirmation email will be sent to you once you have completed the registration form. And after following the confirmation link in said email, you can begin to trade. Note that new accounts have withdrawal limits that are explained above.
Liqui has one verification level, the requirements for which are not published. Getting verified begins with a support ticket at their support site. Assume that for verification, the usual information is required. Namely a photo ID and proof of residence.
Liqui has a soft feel to its interface, which by default is a cool white with blue highlights. Liqui’s interface also offers a dark mode, which can be toggled with the lamp icon at the top of the page. The dark mode maintains the same highlights but trades the light background and dark text for a dark background with light text. Almost all of the interface switches seamlessly, with charts requiring a refresh. Some users may find the dark mode difficult to read, as the contrast between the text and the background is not very high.
On Liquis main trading page, there is a chart and summary front and centre, with buy and sell dialogues below. Further below is an area to select trading pairs, the current order book, trade history, and your personal trade history.
Liqui offers decent security measures, including 2FA. When logging in to your account, without having 2FA configured, you are emailed a security code for that login. The security code is a massive 64 character string, making it safe from brute forcing in the 5 minutes which it works. Two Factor Authentication is offered via Google Authenticator and is simple to set up, using the standard ‘scan this QR code’ approach.
Otherwise, Liqui offers a complete overview of account login activity. Specifically, you can see all active sessions, with the ability to close them, and you can see all login activity, successful or otherwise. Both account information sections have the date, time, and IP address of the occurrence listed.
Coinfloor is a London UK, based cryptocurrency exchange that was founded in 2012. It offers 8 trading pairs, all of which are crypto/fiat. Coinfloor finds itself at number 21 on BlockExplorer’s list of the top 25 cryptocurrency exchanges of 2017.
Coinfloor is a good choice for any UK based trader looking to trade in some of the more well-known cryptocurrencies. Specifically, Coinfloor provides trading pairs for Bitcoin, Bitcoin Cash, Ethereum, Ethereum Classic, Ripple, and Litecoin. Coinfloor’s markets seem active, with XBT/EUR being the most active trading pair.
Trading pairs: 8
Deposit Fees: Yes, for fiat
Withdrawal Fees: Yes, for all
Trading fees: Yes
Verification: Yes, one level
Margin Trading: No
Registration on Coinfloor is broken up into three steps. Step one requires just an email address and password. Once you have completed step one, you must confirm your email via a link before proceeding to step two. Step two requires you to configure two-factor authentication, and step three requires you to go through Coinfloor’s verification system.
Coinfloor has a single verification level that is required to trade on the platform. Getting verified is a two-step process that requires a picture of your ID, your full name, your country of residence (including postal code). According to Coinfloor, the verification process should take about a minute for pre-verification in most cases.
Coinfloor’s trading fee system is broken up into three levels where each level is based on the amount you have traded over the past 30 days. On the low-end, the trading fee is 0.30% of your trading and applies for traders with less than $500,000 USD traded over 30 days. For mid-range, the fee is 0.20%, which applies for traders that have traded between $500,000 USD and $1,000,000 USD over the past 30 days. And on the high-end, for more than $1,000,000 USD traded, the fee applied is 0.10%.
Deposit and withdrawal wise, for cryptocurrencies, there is no deposit fee and there is a small withdrawal fee of 0.0050 of that currency, with a minimum deposit of 0.05 and a minimum withdrawal of 0.0005. Fiat wise, the fees are set per currency and can be seen on Coinfloor’s fee page. Minimum deposit and withdrawal for fiat are 5,000 and 2,000 respectively for every fiat currency that Coinfloor accepts.
Coinfloor’s trading interface leaves a bit to be desired, the entire site is built on a white and blue theme, with the occasional green accent. And unfortunately, there is no dark mode available, making late night trading sessions heavy on the eyes. The main trading interface has a market depth chart, but no other charts are offered. Below the chart on the left is an order book, with your personal orders filtered to the right. Directly to the right of the chart is an order submission form. And on top is a trading pair selection drop-down.
While Coinfloor does enforce 2FA, there are unfortunately only two supported 2FA methods, and Google Authenticator isn’t one of them. The two choices you do have are Authy and YubiKey, with YubiKey being the star of the two, as it’s a hardware-based second factor. Otherwise, Coinfloor will email you on every login to your account.
On the corporate side, Coinfloor states that it maintains all of its client’s currency in multi-signature cold wallets. Also stated is that its entire system is regularly tested by penetration testers, though it does not state exactly who, aside from ‘a highly regarded penetration testing firm’.
Bitcoin Cash was created as a result of a continuing debate in the Bitcoin community about how Bitcoin should scale to meet an expanding user base. Bitcoin Cash branched off from the original Bitcoin blockchain, and all work done previous to the split is just as much part of the history of Bitcoin Cash as it is part of the history of Bitcoin. Because of this shared history, and the disagreements that led to its creation, the status of Bitcoin Cash is hotly debated, with two sides deeply entrenched in their view.
Proponents of Bitcoin Cash believe that they preserved the original Bitcoin by forking off before other controversial changes were applied, mainly the SegWit side chain system. In their view, Bitcoin Cash conforms more to the original version of Bitcoin, and some even go so far as to say it is the true Bitcoin.
Opponents of Bitcoin Cash feel that it was a fork perpetrated by people looking to capitalize on Bitcoin’s success by creating what is essentially just another coin in the market, but unfairly leveraging the name recognition of Bitcoin.
Bitcoin Cash has a very clear and simple goal, which is to be an everyday currency, used as commonly and frequently as any paper cash, credit card, or any other way people transact for goods and services. However, this goal does not exclude the possibility of being a store of value, as proponents of Bitcoin Cash believe that value ensues from the ability to conduct commerce. Also, as of mid-May 2018, Bitcoin Cash will have the ability to do smart contracts similar to what Ethereum can do, and previous to this, developers have already innovated different uses for the Bitcoin Cash blockchain, such as an on chain social messaging system. What turns out to be the most popular use for Bitcoin Cash may yet to be seen.
Bitcoin Cash is mined on the exact same hardware that Bitcoin uses, as they are both forks of the exact same code base. As such, Bitcoin Cash directly competes with Bitcoin for computing power. How much power is split between the two coins is determined by the price of the coins, which determines how profitable they are to mine. Currently, the majority of mining power goes to Bitcoin, as it has a significant price advantage. However, Bitcoin Cash has seen price gains approaching 20% of the value of Bitcoin. If it goes upward, and there is enough incentive for Mining to switch over to Bitcoin Cash, this could present a technical challenge for Bitcoin, as the difficulty algorithm that determines how fast blocks can be mined might not adjust in time to match less computing power being available. In such a case, the Bitcoin chain could see a dramatic fall in value, or even fail to be able to continue entirely. This is one reason Bitcoin supporters feel that Bitcoin Cash is an existential threat to Bitcoin.
Except for a few very short-lived spikes, Bitcoin Cash has held a fairly consistent place as the fourth largest cryptocurrency by market capitalization. As of May 2018, it has closed the gap on Ripple, its price deviating slightly from the rest of the market, which usually tends to rise and fall together. Because of the controversy surrounding Bitcoin, there are those who apply a lot of meaning to its rise or fall, but while the two warring factions rally against the opposing side, hoping to see Bitcoin Cash rapidly become the de facto cryptocurrency or disappear completely, the market seems to have settled on a slow and steady progression that leaves neither side completely satisfied.