A new customer opened an account three days ago with minimal information (name and email only). Today, they attempted to deposit €50,000 in cash using a third-party payment processor.
When prompted by the automated system to complete identity verification, the customer contacted support and stated: "I value my privacy. Cryptocurrency is supposed to be anonymous. I should not need to provide government documents to use my own money."
The customer claims the funds are from selling a family business (cash-intensive restaurant) and wants to "invest in Bitcoin before the price goes up."
- Large transaction immediately after account opening
- Refusal to complete KYC verification
- Cash-intensive source of funds (restaurant)
- Privacy-focused language suggesting possible awareness of regulations
An established customer with a verified account and clean transaction history requests withdrawal of 85 ETH (valued at $125,000) to an external wallet address.
Your blockchain analytics tool flags that the destination wallet has received funds from mixers and has interacted with wallets located in Iran. The most recent deposit to this wallet came from an Iranian exchange 48 hours ago.
The customer states: "This is a business partner's wallet. We're working on a DeFi project together. He's Iranian but lives in Dubai now. The wallet might have Iranian connections but that's just where he used to trade."
- Destination wallet linked to sanctioned jurisdiction (Iran - OFAC sanctions)
- Recent interaction with Iranian exchange
- Mixer usage in destination wallet history
- Claim of relocation to Dubai (common sanctions evasion pattern)
For the past 8 months, this customer has maintained a consistent pattern: deposits of €400-700 every week (presumably freelance payments), occasional small trades between EUR and BTC, and monthly withdrawals averaging €2,000.
In the past 4 days, the account activity changed dramatically:
- Day 1: Deposit of €15,000 from a UK business account (company: "TechConsult Ltd")
- Day 2: Immediate conversion to USDT, then transfer to external wallet
- Day 3: Deposit of €12,000 from a different UK business account ("Digital Solutions LLP")
- Day 4: Deposit of €11,000 from an Italian individual account, conversion to BTC, withdrawal request pending
When contacted, customer states: "I landed three big design projects at once. Companies prefer to pay in crypto now. This is legitimate freelance income."
- 10x+ increase in transaction volume with no advance notice
- Rapid in-and-out pattern (deposits immediately converted and withdrawn)
- Multiple different source accounts across jurisdictions
- Inconsistent with stated occupation and historical pattern
- Possible structuring or layering behavior
A verified digital artist customer sold an NFT artwork for 1,100 ETH (approximately €2,000,000) on OpenSea. The proceeds arrived at their CryptoSecure Exchange wallet, and they now want to cash out €1,500,000 to their French bank account.
Your due diligence reveals:
- The buyer's wallet was created 8 days before the purchase (fresh wallet)
- The buyer's wallet received the 1,100 ETH from a centralized exchange not in our jurisdiction (located in the Cayman Islands, not FATF-compliant)
- No information about the buyer is available (no Travel Rule data provided)
- The NFT had no prior sales history (first-time mint and sale)
- Previous largest sale by this artist was €45,000
The artist states: "I'm thrilled! An anonymous collector found my work and made an incredible offer. In the art world, anonymous buyers are common for high-value pieces. This is a legitimate art sale."
- Extremely high value (€2M) inconsistent with artist's history (previous max €45k)
- Fresh buyer wallet created days before purchase (possible money laundering vehicle)
- Buyer funds from non-FATF jurisdiction without Travel Rule compliance
- No secondary market validation (first sale ever)
- Potential NFT wash trading or value inflation scheme
- Possible tax evasion or sanctions evasion via art market
A representative claiming to act on behalf of "GreenFuture DAO" wants to open an account and convert €5,000,000 worth of the DAO's native token into USDC stablecoin. The funds would be held at CryptoSecure Exchange for quarterly operational expenses.
Information provided:
- DAO has 3,847 token holders worldwide (governance participants)
- Treasury controlled by multi-sig wallet (5-of-9 threshold)
- DAO voted on this treasury management decision (73% approval, 1,247 voters)
- No legal entity registration anywhere
- Representative can provide documentation of the multi-sig signers (9 individuals across 7 countries)
- DAO's stated purpose: fund climate change projects via grants
The representative states: "We need proper treasury management. DAOs are the future of organizations. We have full transparency - all transactions and votes are on-chain. We shouldn't need traditional KYC because we're decentralized."
- No legal entity = unclear who the customer is under MiCA
- Multiple beneficial owners across jurisdictions (9 signers, 3,847 members)
- Cannot perform traditional KYC on a non-entity
- €5M transaction threshold triggers enhanced due diligence under MiCA
- Unclear regulatory treatment of DAOs in EU and US
- Potential securities law implications (DAO governance token)
A 16-year-old applicant wants to open an account with parental consent. The parent has submitted verified ID documents for both themselves and their child. The teen wants to invest birthday money (€500) in Bitcoin as a "learning experience about finance and technology."
Both parent and child have completed video verification calls. The source of funds is documented (bank transfer from grandparents with "birthday gift" memo).
An existing customer was recently appointed Deputy Minister of Finance in Spain. They properly disclosed their PEP status 3 months ago when appointed. Enhanced due diligence was completed at that time, and the account was approved for continued use with source of wealth verification (family inheritance €1.2M documented).
Today, they deposited €75,000 and immediately transferred it to an Ethereum DeFi protocol (Aave) for yield farming. Your blockchain analytics show the funds are now:
- Earning 4.2% APY on USDC deposits in Aave
- Being used as collateral for a small DAI loan (€12,000)
- Interacting with multiple DeFi protocols via automated smart contracts
This creates a complex beneficial ownership question: the customer owns the wallet, but the funds are now controlled by smart contracts across protocols.
A verified customer works in construction in Milan and sends money to family in the Philippines every week. The pattern is consistent:
- Deposit €300-400 from Italian employer bank account (direct deposit visible)
- Immediately convert to USDT
- Transfer to same Philippines-based exchange wallet (verified as major local exchange)
- Family member cashes out to Philippine pesos
The customer uses crypto because "bank wire fees are €25-35 per transfer. With crypto it's €2. I'm supporting my elderly parents and three younger siblings back home."
This is a legitimate use case, but annual volume (€18,000) is approaching thresholds that trigger additional reporting requirements under FATF Travel Rule.
A customer contacts support with an unusual request: they want to deposit 850 Monero (XMR) - a privacy coin with untraceable transactions - and convert it to EUR for withdrawal to their Austrian bank account.
The customer states: "I've been accumulating Monero for 3 years as a privacy advocate. I used it for legitimate purchases and savings. Now I need the money for a house down payment. I can prove it's my wallet - I'll sign a message from the address."
The problem: Your exchange does not officially support Monero trading due to regulatory concerns. However, technically you could accept the deposit, immediately convert to BTC, then to EUR. The customer is offering to pay a 3% premium for this service.
Blockchain analysis is impossible for Monero - you cannot verify the source of these funds or past transaction history. The customer can prove wallet ownership but nothing else.
- Privacy coins inherently resist AML/CTF monitoring
- Cannot perform blockchain analytics on Monero transactions
- No way to verify source of funds or beneficial ownership chain
- €127,500 value triggers enhanced due diligence under MiCA
- Many jurisdictions have delisted privacy coins due to regulatory pressure
- FATF has expressed concerns about privacy coins enabling illicit finance
A customer deposits 42 BTC (approximately €950,000) from a wallet associated with an online crypto casino based in Curacao. They want to convert to EUR and withdraw to their Polish bank account.
When asked for source of funds documentation, the customer provides:
- Screenshots from the casino website showing account balance
- A "VIP player certificate" from the casino
- Transaction history showing numerous bets over 6 months
- Casino's "proof of payout" letter (not on official letterhead, just an email)
Customer states: "I got lucky at crypto poker. I started with 0.5 BTC and played for months. The casino is legitimate - it has a Curacao gaming license. This is legal gambling winnings."
Additional concerns:
- Curacao licenses are known for minimal regulation
- No independent verification of gambling activity possible
- Crypto casinos are sometimes used for money laundering
- Poland has restrictive gambling laws - online casinos may be illegal
- Very high winnings (0.5 BTC → 42 BTC = 84x return) are statistically unlikely
- Curacao licensing is weak regulatory environment
- Gambling proceeds are high-risk for money laundering (FATF guidance)
- Cannot independently verify legitimacy of casino or winnings
- Possible legal issues in customer's home jurisdiction (Poland)
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