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Suspicious Transaction Reports from Virtual Asset Service Providers

Case Study 2: Non-Payment Fraud Scheme Involving Virtual Assets

Several suspicious transaction reports were received by the Financial Intelligence Unit (FIU) regarding a non-payment fraud scheme involving virtual assets.

• A group of criminals promised victims large financial gains through virtual assets, promoting lucrative investments in Bitcoins.
• The main suspect managed to gather approximately EUR 120,000 per day.
• Following national cooperation between the FIU and its competent authorities and international cooperation with foreign FIUs, the main suspect was arrested, and the criminal operation was shut down in July 2019.

Case Study 3: Kidnapping Cases Involving Bitcoin

Several kidnapping cases were reported where the perpetrators demanded a ransom to be paid in Bitcoin.

• In May 2018, a 13-year-old minor was abducted while playing outside with his friends.
• The parents of the boy received a ransom note with instructions to send 15 Bitcoin to a specific Bitcoin address.
• Based on the technical data linked to the Bitcoin address left on the ransom note, the local FIU was able to identify the users of the address.
• The investigation revealed it was a multi-signature Bitcoin address, requiring at least two out of three private keys to access the virtual assets.

Case Study 4: Malware Distributors Demanding Ransom in Virtual Assets

This case study shows an example of malware distributors demanding a ransom in virtual assets for the release of encrypted data.

• An international group of cyber criminals targeted local governments and prominent business entities with the release of ransomware.
• The attacks consisted of the encryption of specific hard drives that would only be decrypted after the victims paid the ransom in Bitcoin.
• Over the period of 2 years and 3 months, a total of 20.16165158 BTC were transferred to Bitcoin wallets linked to the suspects.

FinTech Entities and Regulation

The survey revealed no specific regulation for crowdfunding services/platforms in many jurisdictions.

• A considerable number of respondents indicated that entities offering crowdfunding services/platforms are considered reporting entities in their jurisdiction.
• Approximately 16% of respondents indicated that specific legislation on crowdfunding services/platforms is being considered or is currently pending in their jurisdiction.
• Other FinTech entities, such as the BNPL sector, peer-to-peer lending, or investment management platforms, although not explicitly covered by the questionnaire, seem to be captured under existing definitions of traditional financial services in many jurisdictions.

Identifying FinTech Entities

Many FinTech entities offer their services online, which extends their reach globally. Therefore, a FinTech company providing services to entities in each jurisdiction is likely not domiciled or registered in that same jurisdiction.

• Based on survey responses, cooperation between AML/CFT supervisors and FIUs appears to be an approach commonly used to detect new FinTech products and service providers.
• Generally, the financial supervisor/regulator plays a major detection role in almost every responding jurisdiction.
• In addition, some jurisdictions use open-source information, regular meetings with competent authorities/regulators, and engagement with the private sector, academia, industry associations or technology communities to gain awareness of new developments in the FinTech environment.

Case Study 5: Virtual Assets Laundering Using a VASP

The following case study presents an example of virtual assets laundering, using a VASP to conduct a sequence of transfers between different virtual assets prior to cashing out the funds.