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Money Laundering and AML Compliance
- pjkundert 4y agoGovernor Tarkin: Princess Leia, before your execution, you will join me at a ceremony that will make this battle station operational. No star system will dare oppose the Emperor now. Princess Leia: The more you tighten your grip, Tarkin, the more star systems will slip through your fingers. Every government and central bank in the world is tightening their grip around the tiniest transactions of their citizenry. In the meantime, they are printing Trillions and shovelling it to their sycophantic corporate and political elite buddies. And then, they wonder why people are being driven to use Cryptocurrency... For those of you who are offended by this characterization; how does burdening 8 billion law-abiding Citizens with impossibly complex and arduous KYC/AML requirements make sense -- when just one FTX incident exceeds the value of all legitimate remittance transactions on the planet for the entire year, and KYC/AML doesn't affect the likes of FTX, Tether, etc. in the least? Perhaps you feel like you're "doing something". You are -- making every law-abiding free Citizen feel like a criminal and expend countless hours of life-energy, to do precisely nothing to solve the problem, while crippling the legitimate small business and personal enterprise of the entire planet. Congratulations!
- matheusmoreira 4y ago> And then, they wonder why people are being driven to use Cryptocurrency... If only. Normal people are only buying crypto to speculate. They drive the price up to absurd levels and then write it all off as a scam when it corrects. Meanwhile good technology like Monero remains marginalized instead of replacing the USD as it should.
- pjkundert 4y agoYou seem to be speaking for ... a lot of people you can't possibly know -- such as me, and every person I work with and deal with on a day to day basis in the Crypto R&D field. As for Monero -- don't complain, let's bring it mainstream by building something. Specifically: something that state-level interference can't stop, even if they're quivering in rage that it exists! That's what us "speculators" who code every day on large-scale Cryptocurrency decentralized systems are doing...
- novok 4y agoAlways kind of wondered why monero onlyfans or state weed hasn't happened much. Work that is legal, but the financial system makes an absolute bitch to actually financially transact for.
- matheusmoreira 4y agoI'm wondering to this day. Prudish financial institutions refusing business to "questionable" businesses are one of the problems cryptocurrencies were intended to solve. But when I suggested that here I got called out for it. No idea why there was so much hostility.
- matheusmoreira 4y ago> such as me, and every person I work with and deal with on a day to day basis in the Crypto R&D field. You ended up proving my point. Normal people don't research or develop cryptocurrency technology, they buy and sell it on Binance. It's hard enough for people to understand BTC, the altcoin situation is next to hopeless. > As for Monero -- don't complain, let's bring it mainstream by building something. I've gotten paid anonymously in XMR for a small programming task. It was a wonderful experience, I wish everybody would pay me that way. The technology already already works. If anything still needs to be built, it's even stronger privacy guarantees against the perpetual government encroachment. This is a social problem. How do we get people to drop USD and start using XMR instead? It's a form of the ages old circular logic problem of bootstrapping: nobody uses it to buy things because nobody accepts it, and nobody accepts it because nobody uses it to buy things.
- ClumsyPilot 4y ago> good technology like Monero remains marginalized instead of replacing the USD as it should. Imagine you achieve your Crypto-dream, known mass murderers like the head of Wagner or Kadyrov will move money with impunity. Current system is problematic, but I don't fancy the idea of money being conpletely untouchable by the system of justice
- notch898a 4y agoYeah then law enforcement would actually have to catch Kadyrov for you know, murdering civilians rather than for moving money. That sounds awful.
- deleted 4y ago[deleted]
- matheusmoreira 4y agoI wonder what else you don't fancy. I mean, your argument is essentially the financial version of the "terrorists and child molesters" argument. Do you also support mandated cryptography backdoors because cryptography also protects criminals? All this mandatory financial reporting for "anti-money laundering" purposes or whatever is just the financial arm of the global panopticon. You're defending total global surveillance and control. You're advocating giving up freedom for security.
- ourmandave 4y agoI dunno, I sent Sam Bankman Fried all my Galactic fiat credits, and suddenly couldn't make withdrawals. I called my senator to look into it, but then I find out the Emperor has dissolved the senate.
- TeMPOraL 4y agoCall a Fett. That's what the bounty hunters are for.
- timerol 4y ago> burdening 8 billion law-abiding Citizens with impossibly complex and arduous KYC/AML requirements TFA notes that "This will affect the typical user of the financial system precisely zero times during their lives." It is very much not a complex and arduous situation in most instances, only in very few edge cases. (Which patio11 wants us to pay closer attention to.) I had occasion to unexpectedly transfer $10k over ACH recently, and, while a few minutes on the phone with my bank confirming things was slightly annoying, I would describe it as neither complex nor arduous. I am confident that it did not trigger a CTR or SAR, given it was not a cash transaction, and I was happy to answer a few questions.
- pjkundert 4y agoIhre Papeire bitte. Stop And Frisk. Nobody without something to hide should want privacy/encryption. Forcing 8 Billion people to KYC/AML before buying a coffee or helping a relative isn't too much to ask. Amirite? /s
- JusticeJuice 4y agoFunniest AML thing I ever did. Went to open a new account in the app, it's like sorry you haven't verified your identity can't do it through the app. Okay. Walk into a branch, ask to make a new account. They're like nah, you need to come back with proof of where you live before we can verify your identity. I'm literally standing in front of you. With ID. I already have 3 accounts, what's a 4th?
- omgomgomgomg 4y agoThey would need a recent proof of address to know where you live. I know, it is stupid and there are so many ways to fake this, but a bank cant possibly gibe a loan to someone without knowing where they live. Else kim jong il could just walk in with his id etcetc.
- exbanker 4y agoThis is just factually untrue. AML policies unjustly affect millions of Americans. At US Bank, you can’t deposit cash without an ID which is standard post 2018 or so. Yet go to a US Bank in a low income area, deposit $100 in a family member’s account and they will ask for ID, social security number and your job. US Bank has been involved in multiple money laundering scandals leading to deferred criminal prosecution. Many friends have times where they can’t withdraw their own cash, have had accounts closed, have been falsely reported for fraud without any recourse etc etc. Also because financial fraud and identity theft is rarely prosecuted, regular Americans are bombarded with friction and hassle to transact. People outside normal banking use Chime or prepaid bank cards, which promptly get banned from being used in a wide variety of businesses. AML policies and the Bank Secrecy Act is a violation of the 4th Amendment. The BSA (a misnomer) has expanded in scope since the 70s and as money has inflated. It’s went from an adjusted $70,000+ to $600 today (or $85 in 1970s dollars). And it seems the Supreme Court is going to act on the BSA sometime in the next year. It is a crime against the individual, a violation of civil rights and indefensible. It is purely motivated by tax enforcement and controlling the population. It does not prevent or identify crime. There is an estimated trillion+ of trade based money laundering every year.
- wpietri 4y agoI think it's appropriate you open with Star Wars, as this is mainly fantasy. > burdening 8 billion law-abiding Citizens with impossibly complex and arduous KYC/AML requirements Not sure if you read the article, but they just aren't a significant burden for most people. They could be better, sure. And I think the "driven to use Cryptocurrency" example does not pair at all well with FTX. The massive wave of cryptocurrency failures from Mt Gox to FTX demonstrate beautifully why an unregulated financial system is a terrible idea.
- pjkundert 4y agoNo, you aren’t burdened. The bulk of humanity is, though. The compliance costs in terms of effort/time/money expended per dollar of revenue affected is probably 10x to 100x for them, as it is for you. This has been my experience, and my observation across many life stories. I taught basic finance to hundreds of mid- to low-income families in the 2000’s. So again - a “let them eat cake” admonishion. And FTX was just a massive, traditional fraud. Literally nothing to do with Cryptocurrency, other than as the medium of the fraud. Random charlatans stealing money from gullible and trusting marks. The bulk of the legitimate cryptocurrency platforms continue working. A few that were obvious mathematical impossibilities implode - much like fraudulent businesses have for ages past.
- wpietri 4y ago> No, you aren’t burdened. The bulk of humanity is, though. I look forward to somebody demonstrating that. The author of the article, a domain expert, thinks otherwise. > And FTX was just a massive, traditional fraud. Literally nothing to do with Cryptocurrency, other than as the medium of the fraud. Other than the medium, the culture, the community, the domain, and the regulatory vacuum of cryptocurrency. So a great deal to do with it. And it's not as if it's an outlier for the space. If it's really the burden you are concerned about, you might look again at cryptocurrency. The burden just to use it is relatively high. Then there are the higher caveat emptor burdens. And then we get to the vast, vast sums lost through volatility, exchange costs, user error, incompetence, fraud, and theft. Being upset about KYC/AML and not about that is a situation of motes and beams.
- psobot 4y agoEvery post from patio11 is such a joy to read: precise, exact, descriptive, and entertaining. I'd love to understand where his writing style comes from and how to emulate it.
- mablopoule 4y agoAgree, It's the perfectly balanced between "too dry/academic", or "too vague/gimmicky". It's often mentionned in HN, but in the same style, I cannot recommend enough "Money stuff" [1] which is Matt Levine's newsletter at Bloomberg. Highly entertaining. [1] https://www.bloomberg.com/opinion/articles/2023-02-06/musk-gets-away-with-mischief https://www.bloomberg.com/opinion/articles/2023-02-06/musk-g...
- abdullahkhalids 4y agoI really hope he compiles these blogposts into a book. There is so much nuanced industry knowledge here. > I'd love to understand where his writing style comes from and how to emulate it. In the "good old days" they made students memorize passages from great authors and reproduce them. The idea being that this process will force you to think about the structure of their sentences and vocabulary. I used to do this when I was a kid, but I don't think I did it enough to have an impact.
- skybrian 4y agoI think it's a witty and knowing but rather opaque writing style that's designed to make you work. Often worth the effort, but he could use an editor or beta tester to help dial it back a bit. There were a few times when I almost sent him a tweet that he got some logic backwards, but after rereading, I realized that I had misread it, that it's right but confusing.
- patio11 4y agoI hope to hire an editor one of these days, but some of my characteristic style is intentional and some is just a reflection that the production function is "Crikey I've put the kids to bed and now have checks watch four hours to write prior to my effective deadline."
- irusensei 4y agoIt is expensive to keep a crime and corruption department on your banking institution. If you are dealing with a millionaire who is related to some oil mogul in Russia you can do your due diligence and Vladimirovich can hire a team of accountants to prove that his business is legit and not at all related to the corporativist oligarchy his uncle runs. Or it might be, but the risk vs reward is good enough to turn a blind eye for now. Ivan, immigrant from Belarus who drives a bus and likes to withdraw cash from his <5000 euro account? Get this living liability out of my bank! I won't run a whole department or risk getting fined because some no name pauper. But since we can't just ban him let's just ask for ridiculous documents like proving the nationality of his grandfather (real story btw) or criminal records, translated in English, by an official translator. Let's annoy him so much with retarded requirements he will leave by himself and if he fails to provide our totally not arbitrary evidence we write a polite e-mail stating that we are sorry but we won't run his account anymore. That's basically AML compliance to you.
- malux85 4y agoAlso - wait until Ivan has put 10k in your system, then ask for the documents and refuse to give the money back hoping he will abandon it. - Lawful evil AML companies
- notch898a 4y agoOr send him a check for the balance and then put derogatory information under chexsystems and all the other banking blacklists so it can't be cashed.
- irusensei 4y agoI think I’ve heard someone calling this shotgun KYC. They will allow you to deposit but as soon as you show signs of using that money they take it as hostage until you prove you are not a criminal.
- cmeacham98 4y agoCommon with offshore online casinos: you can deposit and lose your money, but as soon as you try to withdraw winnings the KYC rolls out and you better hope you're not a US citizen because you weren't even supposed to sign up in the first place then.
- notch898a 4y ago[flagged]
- JusticeJuice 4y ago> Ban the US gov from the finance system At the cost of what, cutting of millions of people from benefits? Public servants not getting paid?
- notch898a 4y agoDo you protest when a hitman can't do another hit or access his corrupted proceeds to pay his maid or or pay his kid's dental bills? If you are an employee or dependent of a violent organization, the 'unfortunate' effect is someday people may no longer want to do businesses with that organization or its corrupted money.
- Our_Benefactors 4y ago> Do you protest when a hitman can't do another hit or access his corrupted proceeds to pay his maid or or pay his kid's dental bills? No, I would not protest freezing the account of a hitman. Now please show me how I can hire a govt sponsored hitman with USD and I’ll lend your argument some credence.
- notch898a 4y agoThey don't need you to hire them, they just steal your money and do it. Here's some great examples! https://en.wikipedia.org/wiki/Civilian_casualties_from_U.S._drone_strikes https://en.wikipedia.org/wiki/Civilian_casualties_from_U.S._... edit: lol person below appears to have no idea what an analogy is... nor the fact I was referring to fellow violent instigators of violence and not literally restricting it just to the ones a specific HNer can readily hire for a specific task. But fucking weird to ask, not to mention their solicitation may be a crime.
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- coderintherye 4y agoExcellent write-up. Key point is, no one truly looks at the efficacy of AML which makes it more theatre than crime-fighting tool (not that it doesn't fight crime, it just does not do so efficiently nor is it likely the best way to do so, let alone us defining broadly what crime actually is). If these systems were re-designed from the ground up, AML procedures and policies would likely look quite different than they do today.
- miohtama 4y agoThe problem with compliance is that it is pseudoscientific. There is no independent oversight: all regulation and tools are promoted by compliance companies selling those tools. There is no penalty for punishing innocent. There is no reasonable cost. More is always better. There is no court to complain or a channel to opt out. It's a bit like antivirus on PCs: it is sold to you as a scareware but in practice is snakeoil not really effective against any modern virus or trojan. You stil bear the cost of your PC slowing down 25%. Here is a good Forbes post by David Birch on the topic: https://www.forbes.com/sites/davidbirch/2021/05/03/im-anti-the-anti-money-laundering--rules/amp/ https://www.forbes.com/sites/davidbirch/2021/05/03/im-anti-t...
- richbell 4y agoAnecdotally, I know of at least one large FI that tells auditors it's doing x, y, and z for security, when in reality their security practices are abysmal. They spend $1MM a year on a vendor product that in theory does x, y, z (though quite badly), install it on a server, and then never think about it again. I've had important projects canceled because executives go 'oh we already have $tool this project is a waste of time'. I demonstrate that $tool hasn't been updated in a decade, has 0 users, and is completely ineffective, and how the project will address these issues. They respond 'oh we already have $tool this project is a waste of time'.
- miohtama 4y agoYou are not buying a solution, you are buying compliance. It does not matter if problem is either hidden or removed because the outcome for the executive success is the same. Hiding usually costs less.
- timcavel 4y ago[dead]
- yieldcrv 4y agoAl Capone would have passed KYC
- NovemberWhiskey 4y agoAl Capone would fail KYC just on reputational risk and negative media exposure before we even get into unclear source of wealth.
- yieldcrv 4y agoEveryone can get banked unless they didn't pay overdraft fees (in Chex Systems in some way). All he needs is one bank and brokerage firm for total access to the domestic and international electronic banking system. There are enough around. All the major ones would take his account. Negative media exposure lol, as if this is publicly broadcasted, but even then, those fees would be enticing.
- from 4y agoYes but most likely his wife or son wouldn’t show up in World-Check or whatever compliance system they use nowadays. Instead of engaging in this hypothetical we can just look at the million examples where modern day multi millionaire criminals passed KYC, to which the usual suspects will say “well that wasn’t real KYC” or “we have since closed those loopholes” which they have been saying for the past 30 years. This weird experiment of outsourcing crime enforcement to banks does not work and I’m not sure why this massive consensus exists that it does.
- AlbertCory 4y agoDo you mean KYC now, or what passed for KYC in the 20s? Before he got busted by the Feds, he went to baseball games and posed for pictures, and "respectable" people might be seen with him. I don't think he'd ever have been invited to the White House, though. As someone else here said: no, the "reputational risk" would doom him now.
- yieldcrv 4y agothis is so cute I dont even want to bother explaining it How are we on a KYC thread, with people that actually do KYC, believing their koolaid They see the accounts They know the gaps in the regulatory framework, or should They should know the pointlessness of this exercise but apparently the idealism (or a couple internal examples I’m unaware of) is convincing still and masquerades as reality KYC is as strong as the weakest link in all financial institutions and all pooled accounts I’m out
- wcunning 4y agoThe best thing I've read on this topic is from Matt Levine at Bloomberg, restated in his newsletter on Wednesday: "In general, the chief compliance officer at any company has a dial in front of her that she can turn to get More Crime or Less Crime, and at a normal company — a bank, for instance — her job consists of (1) turning it most of the way toward Less Crime, but (2) not all the way, and (3) acting very contrite when politicians and regulators yell at her about the residual crime. “We have a zero-tolerance policy for crime,” she will say, and almost mean."
- ghayes 4y agoThe referenced article: https://www.bloomberg.com/opinion/articles/2023-01-05/coindeal-s-bentleys-weren-t-real https://www.bloomberg.com/opinion/articles/2023-01-05/coinde...
- mikaraento 4y agohttps://archive.is/eoiwi https://archive.is/eoiwi
- patio11 4y agoI also think this is a very important mental model for the job to be done of Compliance departments, and I think I cited it in the KYC piece.
- josephcsible 4y ago> At many institutions, one SAR is a non-event. Two, for a retail client, means one gets a letter saying the bank wishes you the best in your future endeavors and will not bank you anymore. That letter will often mention that this is a commercial decision of the bank and will not be reversed. Some clients receiving that letter will, on attempting to open account at a different bank, get refused because the first bank entered them into Chexsytems as “account closed at bank’s discretion” and the second bank, on reviewing that entry, said “yep, we are not touching this hot potato.” > Frustratingly, regulators will say “Well, that is the bank’s decision. We didn’t direct them to do that.”, even though the purpose and effect of AML regulations is causing a lot of behavior not specifically asked for. Banks will, meanwhile, say “Our hands are tied. Look at these enforcement actions. Clearly, this is an unacceptable level of risk.” And meanwhile, there is an actual person who has done nothing wrong and now finds themselves somewhere between greatly inconvenienced and frozen out of the financial system entirely. Why is there so much opposition to "you can't have a bank account anymore because when you had one, one of your checks would bounce almost every week", but so little opposition to "you can't have a bank account anymore for something that doesn't constitute proof of wrongdoing"?
- yttribium 4y agoThe former affects blacks, which are a recognized political constituency. The latter allows you to debank your political opponents (cf Operation Chokehold), which is useful.
- habinero 4y agoDon't be gross.
- kasey_junk 4y agoBecause the former is a straw man as is the latter? Do you have a specific policy you are concerned about that we could rationally talk about or only talk radio talking points?
- deleted 4y ago[deleted]
- exbanker 4y agoThe biggest money launderers are close to those who write the AML policies. One of the most significant money launderers is a famous attorney from Shearman and Sterling in NYC. From my experience, prominent financial executives attempted to engage in blatant laundering of drug money in BVI. These individuals were connected to the attorney and one is a public official appointed by 4 US Presidents. This was 20+ years ago and I don’t know what they actually did, but I was in the room when they tried to do it. Outside the room hung a giant photo of George W. Bush golfing with the firm’s CEO. They offered me $1 million in cash to fly with $100m at a time to Tortola. The financial structure was created by the attorney.
- mmerlin 4y agoThanks to the Wikileaks effect of the internet (rapid info declassification + sharing) more corruption is able to be exposed, and the scale is shocking and enormous. The hardest part is then trying to change a known-to-be-corrupt system, when those who write the rules always do so in their favour. Here in Australia we have slid into the bottom 10 percent of global corruption index [0] Politicians, lawyers, accountants, and realestate agents have conspired to repeatedly prevent AML from being introduced to Australia since 2002. Whistleblowers get threatened with life-destroying jail terms. Politicians "retire" then take up cushy directorships with numerous companies they previously wrote seemingly treasonous laws for (dozens of slap-in-the-face-blatant corruption yet it continues on with impunity or any punishment except for maybe losing an election or a gravy train contract). [0] https://www.transparency.org/en/blog/cpi-2021-corruption-watch-list-australia-austria-el-salvador-kazakhstan https://www.transparency.org/en/blog/cpi-2021-corruption-wat...
- sjy 4y agoSource shows the opposite: although Australia is declining in the rankings, it remains in the top 10% of least corrupt countries.
- mmerlin 4y agoThanks you are correct and I will fact check my posts a bit more next time. I thought our last 15 years of politicians were massively unaccountable and corrupted by self-created taxpayer slush funds plus lobbyist megabucks, corporate kickbacks and post-politics directorships. I suppose politicians everywhere are essentially driven by the same human frailties, yet mostly worse than what I am seeing locally!
- deleted 4y ago[deleted]
- JusticeJuice 4y agoExcellent essay. The 10k rule mentioned is totally a thing. I was at a company implementing AML for the first time, and the compliance team told us to add it, which I always thought was an inane. They came up with a variety of rules with just arbitrary figures in them, including the 10k rule. Didn't matter if you had previously been transacting 7k regularly before jumping to 10k, didn't take overall volume into account, didn't look for unusually high acceleration of transactions. Just a magic number pulled out of industry precedents. The interesting thing was if you read the actual legislative requirements it was excessively vague, like "take reasonable steps to find suspicious transactions". Institutions don't build software if they don't have to. The goal always was to do the minimum to check the box, not actually find laundered money.
- raincom 4y agoThese days, AML algos look at cash transactions in a sliding window fashion: $2k ATM deposit on Jan 1, 2022; $3k cash deposit on Jan 21, 2022; $3k cash deposit on Feb. 28, 2022; $3k cash deposit on March 18, 2022. Boom, in the span of 3 months, $11k cash deposits, back office (not tellers) can file a SAR.
- nulbyte 4y agoSort of. If these are normal transactions given the customer's trade, no report is made. SARs are only filed if you are suspicious (that's what the S stands for) that a crime has occurred. This is where knowing your customer comes into play. CTRs, on the other hand, have a limit of $10,000, and while it is aggregate, it's aggregated over a single business day. CTRs do not require suspicion. They are routinely filed for ordinary, legal transactions.
- raincom 4y agoJust go to bankersonline.com and see the kind of responses there. These AML folks rather file SARs for every trivial thing than otherwise.
- diognesofsinope 4y ago
- datavirtue 4y agoNowhere these articles written by chatGPT? If an editor were involved the articles would be about a paragraph each or they they would have been put through the shredder. I have been in the industry for years. The author said nothing enlightening or important.
- patio11 4y ago<Actually ChatGPT> Thank you for taking the time to provide your feedback. I appreciate your perspective and years of experience in the industry. ... I apologize if the articles did not meet your expectations. Thank you for your comment, and I hope you will continue to engage with the content in the future. </Actually ChatGPT>
- EVa5I7bHFq9mnYK 4y agoStopped reading those articles long ago. Straight to the comments section.
- lebed2045 4y agoHow do I know your comment is handwritten and not chatgpted?
- e28eta 4y ago> In part this is because some Americans in the financial industry will involve HR if you describe money as having a color other than green. There are, of course, many speakers of English for whom the history and current relevance of U.S. race relations do not pose strong concern relative to, for example, domestic public corruption I’m disappointed this is the way patio11 chose to summarize why we’re reducing the usage/connotations of “white = good; black = bad” in various contexts.
- AviationAtom 4y agoYou should see how much extra work the campaign is causing in the information security field. Everything has to be rewritten.
- EVa5I7bHFq9mnYK 4y agoAML and KYC really took ground around 2001. The 9/11 was the pretext, but the real reason was because there was now a technical possibility to electronically track all the transactions. How we managed to live and fight crime without it for the previous millennia is a mystery.
- szszrk 4y agoA bit of a quick side story: A bank I worked for set up a lock for all business sites on their firewalls and WAF for any IP geolocalized as Russian. It just dropped or rejected all network packets completely. Individuals could still use their service, though. It was like that since at least a decade ago, since original Russian attack on Ukraine and I have not heard of any issues they run into with that approach. The just went "no".
- _2uwr 4y ago[dead]
- andbeyond 4y agoMy issue with these laws is that they only seem to apply to individuals with little means and not to big corporations. JP Morgan for instance, sends Swift transfers that are not AML compliant. They don't give a toss and nobody will ever look into their practices. But if you're a small merchand on an e-commerce platform, you'll get a horde of lawyers harrassing you with KYC.
- nyanpasu64 4y agoMy hope is that someday people will be able to open bank accounts and transfer money online without revealing their deadname to the bank, having it shoved in their face in bank websites and emails and phone calls, and doxxed to everybody sending them payments for purchases, or even a $1 donation over Ko-Fi.
- dmichulke 4y agoTechnically, that's one of the goals of Bitcoin + inflation security (not stated in your "wish") - electricity consumption (which will be halved every 4 years unless BTC price rises) - volatility (to be seen) Complete (instead of pseudo-) anonymity and low cost of transaction (< 1 ct) is likely to be achieved using Lightning.
- jdblair 4y agoIf you are a US citizen and you have any kind of middle class life that crosses international boundaries, you quickly become familiar with many of these terms and processes. Hold a balance in a foreign bank? File a FBAR (foreign bank account report). Move large sums of money? Be prepared to document the source of the funds. I'm now practiced at preparing bundles of PDFs that show a "paper" trail. BTW, filing a FBAR requires you to report the maximum balance in an account, something that most definitely is not reported on a bank statement unless you hold the balance for more than a month. This is hardly ever the case in an active account.
- nraynaud 4y agoIt’s crazy how we all live in easy Germany now. Governments keep files on everybody and when they decide to go after someone try to find a crime in one of those files.