Knowing your bitcoin customer: A survey of bitcoin money laundering services and technical solutions for anti-money laundering compliance

Abstract

Cryptocurrencies are gaining significant attention and financial investment. Among the wave of new cryptocurrencies, the first cryptocurrency introduced, Bitcoin, remains the most notable and most heavily used.\nWhile Bitcoin is often perceived as an anonymous system, it is in fact only pseudonymous and a variety of methods are known to reidentify the holders of Bitcoin wallets. As a result, services have emerged which ``anonymize" Bitcoin by making it difficult to trace the origin of Bitcoin funds. These services are referred to as ``mixers" or ``tumblers," but are more generally methods of laundering Bitcoin funds.\nIn the United States, a system of anti-money-laundering (AML) regulations developed since the 1970s requires financial services organizations to take positive steps to identify their customers, prevent use of their services for money laundering, and detect and report customers which appear to be engaged in money laundering.\nThese AML regulations have been interpreted by the primary regulator, FinCEN, as fully applicable to Bitcoin. This creates a clear conflict with laundering services which are directly intended to prevent organizations identifying the possessor of funds.\nThis thesis explores the advancing state of both Bitcoin laundering services and Bitcoin anti-laundering services intended to assist in compliance with AML regulations. The current state of the art in both laundering and anti-laundering services is explored. Later, current research and avenues for improvement in these services are discussed.\nUltimately, the way forward for Bitcoin AML regulation is discussed. The current regulatory approach to Bitcoin is insufficient to mitigate laundering with Bitcoin and should be refocused.