John Zasada, Compliance Consulting Director, Financial Institutions Group

On August 10, 2021, the Financial Crimes Enforcement Network (FinCEN) assessed a $100 million civil money penalty against BitMEX for willful violations of the Bank Secrecy Act.

Details shared how BitMEX, one of the oldest and largest convertible virtual currency derivatives exchanges, failed for over six years to implement and maintain a compliant anti-money laundering program. The organization conducted at least $209 million worth of transactions with darknet markets or unregistered money services businesses, as well as conducted transactions involving high-risk jurisdictions and alleged fraud schemes. BitMEX did not file a Suspicious Activity Report (SAR) on at least 588 specific suspicious transactions and lacked an effective customer due diligence process to verify customers’ identity.

In addition to the $100 million penalty, BitMEX must engage an independent consultant to conduct a SAR lookback analysis to determine if the organization must backfile additional SARs.

Doeren Mayhew’s regulatory compliance specialists understand the unique BSA requirements. Should you need help with your BSA program, contact us today.