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Powerful Two-Hander
Mar 10, 2004

Mods please change my name to "Tooter Skeleton" TIA.


divabot posted:

i expect they'll actually have to pay a fortune to a consultancy

I actually know someone that works for one and we send each other ridiculous crypto stories. we were just laughing at binance yesterday.

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evilweasel
Aug 24, 2002

I wonder how one gets the job as binance monitor because that sounds like a very fun gig

notwithoutmyanus
Mar 17, 2009

divabot posted:


So yeah, I think this is intended as a death sentence for Binance - and it's a warning to everyone else in crypto.

All the crypto dipshits I've seen are firmly in bull market celebration mindset. They have basically brushed off this entire situation as a Binance victory because CZ "won't go to jail" (their perspective) and focusing on Blackrock ETF's and that blackrock magically must make Crypto happen.

Until the US gets Dubai to gently caress off from being an explicit money laundering haven, I don't think we'll see enough of a response from crypto idiots.

Vs John Reed Stark who is a pretty reliable authority. https://twitter.com/JohnReedStark/status/1727043783718482238?t=RT6R3NMHiVc1QEcUDiDR0A&s=19

FAUXTON
Jun 2, 2005

spero che tu stia bene

divabot posted:

the Crypto.com guy, Kris Marszalek, has the sort of history you'd expect of a crypto guy. He ran a discount voucher company that collapsed in 2016 and stiffed everyone for instance.

Binance has been handed what might be a worse fate than being shut down - the compliance obligations will be crippling. We wrote it up here with a long quote from David Silverman, a compliance guy who's got a surprisingly fun book on compliance coming out in January.

He says that basically Binance got the sort of compliance penalty that a badly behaved bank gets. A bank is in a real finance business that doesn't require crime, so compliance is a goddamn PITA but they'll live. Businesses that run on crime are unlikely to survive if they can't do crimes any more.

Our esteemed colleague FAUXTON probably has useful opinions on this.

FinCEN has gone into quite a bit of regulatory clarity as to precisely how Binance will hire the various compliance teams that are now required of it.

The other part is: anyone with "compliance" in their linkedin has been getting dumb and bad job offers from crypto exchanges for the past two years. The crypto guys are desperate to hire on compliance, but nobody who's any good wants to work for these bozos. I don't know how Binance is going to find someone to do this job who will pass FinCEN review.

So yeah, I think this is intended as a death sentence for Binance - and it's a warning to everyone else in crypto.

yeah in real banking the feds tell you what to do, how to do it, how many people it's likely going to need, how long it should take etc. You have to explain all your actions to them and basically be on truth serum because they'll come back after you've thought you've covered all your bases and forgotten and make you do a lookback and find stuff. Exams are rigorous even under normal circumstances and most real banks will have some kind of post-exam 'we made it' thing for the relevant staff, not so much a party but like a meeting with catering. Maybe a party if you close a bunch of longer term items and get a clean sheet after like 3 years of work.

The whole "culture of compliance" thing is really just having a whole lot of processes internally that make doing the right thing the easiest/fastest. Unfortunately, the other side of this coin is that it's slow, grinding work to unfuck even a small bank that isn't breaking laws but has deficiencies. If you're a crypto exchange and/or you're dumb enough to think boiler room is a documentary then, well,

koolkal
Oct 21, 2008

this thread maybe doesnt have room for 2 green xbox one avs
I imagine anyone doing compliance for crypto has to be worried about their own liability for whatever crimes are committed afterwards right?

Like you basically have to be constantly telling them they shouldn't be doing something and then make sure you're documenting every objection which sounds stressful

shackleford
Sep 4, 2006

lmao SBF trading fish for a haircut

https://www.businessinsider.com/ftx-ftx-trading-fish-in-prison-for-services-crypto-2023-11

qirex
Feb 15, 2001

he’s going to get shanked when his elaborate preserved fish futures scheme blows up

notwithoutmyanus
Mar 17, 2009
All in on pfishcoin

FAUXTON
Jun 2, 2005

spero che tu stia bene

quote:

The other part is: anyone with "compliance" in their linkedin has been getting dumb and bad job offers from crypto exchanges for the past two years. The crypto guys are desperate to hire on compliance, but nobody who's any good wants to work for these bozos. I don't know how Binance is going to find someone to do this job who will pass FinCEN review.

oh god biiiig confirm, there's been some funny ones.

Chris Knight
Jun 5, 2002

me @ ur posts


Fun Shoe

FAUXTON posted:

crackping lmao
kraken ping

JAnon
Jul 16, 2023


qirex posted:

he’s going to get shanked when his elaborate preserved fish futures scheme blows up

in other words he's gonna BE a preserved fish soon

gschmidl
Sep 3, 2011

watch with knife hands

Sam Fried-Bacalhau

Deep Dish Fuckfest
Sep 6, 2006

Advanced
Computer Touching


Toilet Rascal
i suppose crypto exchanges do have one advantage when it comes to bringing them into compliance compared to other financial institutions: normally you'd probably have to audit all the processes in place and figure out what needs to be fixed, but with crypto there just aren't any so you can skip that step

notwithoutmyanus
Mar 17, 2009

JAnon posted:

in other words he's gonna BE a preserved fish soon

Chub Mackerel-Fried

haveblue
Aug 15, 2005



Toilet Rascal
salmon bassman-fry

drk
Jan 16, 2005

shackleford posted:

lmao SBF trading fish for a haircut

charlie shrem's mackerelcoin is back, baby

Chris Knight
Jun 5, 2002

me @ ur posts


Fun Shoe
mackerelmore's griftshopping

Boxturret
Oct 3, 2013

Don't ask me about Sonic the Hedgehog diaper fetish
what is it with all these bitcoinmen and prison fish

FAUXTON
Jun 2, 2005

spero che tu stia bene

Deep Dish Fuckfest posted:

i suppose crypto exchanges do have one advantage when it comes to bringing them into compliance compared to other financial institutions: normally you'd probably have to audit all the processes in place and figure out what needs to be fixed, but with crypto there just aren't any so you can skip that step

right so you have to look at their records and piece together how hosed they are from the mountains of evidence on hand, then develop remediation to a) screen the existing stuff looking backwards for anything you missed *under the new systems you have developed* and then also have demonstrable success in implementing and operating those controls (meaning rules and procedures, not GUI/buttons)

Remediation is painful if you're in that situation because you're building a system of controls from scratch and have to implement it while the examiners know everything you're doing. In binance's case they're not just having examiners over to take a look, but instead having someone there full time going through everything and taking notes. Reading the indictment/enforcement doc it seems like CZ's big saving grace is that the company was pretty comprehensively loving around, unlike FTX where it's Sam and his polycule looting the coffers and imploding the company. Binance might have ultimately ended up there but they got caught early and CZ gets to kinda skate off because for now there's no pile of shrimp and meth with his name on it, but plenty of chatlogs/emails saying "oh yeah we're busting sanctions don't tell anyone, if an SDN needs a new account help them avoid sanctions using this approach" which is substantially more diffuse in terms of responsibility. It's not only individual actors, but the whole-rear end company. FTX might have made it to this stage had they not taken all the money, but Sam is a special boy.

That's *just* my reading on the aml/sanctions stuff, I didn't delve into how much embezzlement/misuse binance has going on because those broader cap risk controls are not my side of things, I stick to the loud crimes side of compliance.

FAUXTON fucked around with this message at 20:43 on Nov 23, 2023

rowkey bilbao
Jul 24, 2023
my coworkers believe the CZ thing happened because the US want to bring forth an american monopoly over the whole crypto ecosystem by seizing a major player. the dollar isn't a thing and america needs control over a fake economy I suppose vOv.
yes we touch computer at a bank

FAUXTON
Jun 2, 2005

spero che tu stia bene

rowkey bilbao posted:

my coworkers believe the CZ thing happened because the US want to bring forth an american monopoly over the whole crypto ecosystem by seizing a major player. the dollar isn't a thing and america needs control over a fake economy I suppose vOv.
yes we touch computer at a bank

your coworkers fuckin need seroquel and a chaperone

qirex
Feb 15, 2001

the developers at the banks I worked at had pretty much no interest in how the whole money/finance thing worked, they mostly just wanted jobs not at startups and to be left alone to work on their story queue

Chalks
Sep 30, 2009

we need to find out why the us would be interested in arresting someone who has committed 1.6 million crimes

FAUXTON
Jun 2, 2005

spero che tu stia bene





lol the fine alone is more than the profits taken over more than 5 years, and then they're forfeiting an extra two and a half billion.

Chris Knight
Jun 5, 2002

me @ ur posts


Fun Shoe
good.

Hel
Oct 9, 2012

Jokatgulm is tedium.
Jokatgulm is pain.
Jokatgulm is suffering.

qirex posted:

the developers at the banks I worked at had pretty much no interest in how the whole money/finance thing worked, they mostly just wanted jobs not at startups and to be left alone to work on their story queue

Not caring about the money is also very good when something goes wrong, because it means it's just a bunch of incorrect numbers, not more money missing than you are ever going to see in your entire life. Less stress that way.

Deep Dish Fuckfest
Sep 6, 2006

Advanced
Computer Touching


Toilet Rascal

FAUXTON posted:

Binance might have ultimately ended up there but they got caught early and CZ gets to kinda skate off because for now there's no pile of shrimp and meth with his name on it, but plenty of chatlogs/emails saying "oh yeah we're busting sanctions don't tell anyone, if an SDN needs a new account help them avoid sanctions using this approach" which is substantially more diffuse in terms of responsibility.

so what i'm getting from this is that we should throw everyone who works at binance in jail

i'm ok with that

Deep Dish Fuckfest
Sep 6, 2006

Advanced
Computer Touching


Toilet Rascal

rowkey bilbao posted:

my coworkers believe the CZ thing happened because the US want to bring forth an american monopoly over the whole crypto ecosystem by seizing a major player. the dollar isn't a thing and america needs control over a fake economy I suppose vOv.
yes we touch computer at a bank

rather ironic that seraph works at a bank handling filthy fiat

FAUXTON
Jun 2, 2005

spero che tu stia bene

Deep Dish Fuckfest posted:

so what i'm getting from this is that we should throw everyone who works at binance in jail

i'm ok with that

oh don't get me wrong I'd prefer to see them thrown not into jail but into a large cenote.

You can turn electricity into crimes with far greater efficiency by tazing a cop but I'd recommend against that as strongly as I'd recommend against crypto because you're doin' crimes both ways.

RPATDO_LAMD
Mar 22, 2013

🐘🪠🍆

divabot posted:

The other part is: anyone with "compliance" in their linkedin has been getting dumb and bad job offers from crypto exchanges for the past two years. The crypto guys are desperate to hire on compliance, but nobody who's any good wants to work for these bozos. I don't know how Binance is going to find someone to do this job who will pass FinCEN review.

So yeah, I think this is intended as a death sentence for Binance - and it's a warning to everyone else in crypto.

well "working compliance for fraudlords who are 100% gonna disregard everything you say" would suck rear end,
but "working compliance for fraudlords who are currently staring down the barrel of a regulator's loaded gun, and who know you can reach the trigger" seems a lot more fun.
since the regulators are actually requiring them to hire on compliance it sounds like we're now in the second scenario

kw0134
Apr 19, 2003

I buy feet pics🍆

"do what I tell you or you spend the rest of your natural life in federal pen" is a pretty good incentive, yes.

Deep Dish Fuckfest
Sep 6, 2006

Advanced
Computer Touching


Toilet Rascal
sam would disagree, but he's currently occupied trying to create a sort of combination shrimp/meth substitute out of canned tuna, nail clippings, and pruno

Alan Smithee
Jan 4, 2005


A man becomes preeminent, he's expected to have enthusiasms.

Enthusiasms, enthusiasms...
why would mackerel be the new currency, that poo poo don't keep

hodling sugar buns ftw

notwithoutmyanus
Mar 17, 2009

Deep Dish Fuckfest posted:

rather ironic that seraph works at a bank handling filthy fiat
Oh no he absolutely fits the loud moron type that works there. That's common at tons of banks, little wannabe -king fragile snowflakes who own their own little corner of self perceived importance. And they all buckle under the slightest bit of authority from their supervisors.

notwithoutmyanus fucked around with this message at 00:50 on Nov 24, 2023

FAUXTON
Jun 2, 2005

spero che tu stia bene

notwithoutmyanus posted:

Oh no he absolutely fits the loud moron type that works there. That's common at tons of banks, little wannabe -king fragile snowflakes who own their own little corner of self perceived importance. And they all buckle under the slightest bit of authority from their supervisors.

These folks always come from the sales floor and think they're hot poo poo because they learned something new (excel)

Weatherman
Jul 30, 2003

WARBLEKLONK

notwithoutmyanus posted:

Oh no he absolutely fits the loud moron type

well yes, OP did say "seraph"

...!
Oct 5, 2003

I SHOULD KEEP MY DUMB MOUTH SHUT INSTEAD OF SPEWING HORSESHIT ABOUT THE ORBITAL MECHANICS OF THE JAMES WEBB SPACE TELESCOPE.

CAN SOMEONE PLEASE TELL ME WHAT A LAGRANGE POINT IS?
sam's gonna jailbreak

divabot
Jun 17, 2015

A polite little mouse!

koolkal posted:

I imagine anyone doing compliance for crypto has to be worried about their own liability for whatever crimes are committed afterwards right?
Like you basically have to be constantly telling them they shouldn't be doing something and then make sure you're documenting every objection which sounds stressful

RPATDO_LAMD posted:

well "working compliance for fraudlords who are 100% gonna disregard everything you say" would suck rear end,
but "working compliance for fraudlords who are currently staring down the barrel of a regulator's loaded gun, and who know you can reach the trigger" seems a lot more fun.
since the regulators are actually requiring them to hire on compliance it sounds like we're now in the second scenario

yep. FinCEN has to approve the compliance monitor and the monitor reports back to FinCEN. loving around here will not go well for Binance.

This is the FinCEN consent order (PDF). Look at "Undertakings", p59 to p71. FinCEN go into some detail about what they expect - though less detail than a bank would get. Read through that and just imagine crypto bozos trying to understand what any of this poo poo is. Also, lol.

When HSBC were saddled with a monitor, the "monitor" was a whole department of consultants and HSBC set up a whole department to interact with them. But HSBC (a) have a large non-fraud business (b) know how to do this poo poo.

FAUXTON posted:

right so you have to look at their records and piece together how hosed they are from the mountains of evidence on hand, then develop remediation to a) screen the existing stuff looking backwards for anything you missed *under the new systems you have developed* and then also have demonstrable success in implementing and operating those controls (meaning rules and procedures, not GUI/buttons)

a bit like what John Jay Ray had to do at FTX in reconstructing basic accounts from scratch

FAUXTON posted:

That's *just* my reading on the aml/sanctions stuff, I didn't delve into how much embezzlement/misuse binance has going on because those broader cap risk controls are not my side of things, I stick to the loud crimes side of compliance.

i think binance ripped people off in pieces via market crimes and not by just stealing the customer money

this settlement covers the CFTC allegations of market crimes, but not the SEC ones

Powerful Two-Hander
Mar 10, 2004

Mods please change my name to "Tooter Skeleton" TIA.


I'm pretty sure I saw a linkedin post that was heavily implying that this is good for crypto, actually, because it means it's being treated like a real bank lol

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FAUXTON
Jun 2, 2005

spero che tu stia bene

divabot posted:

yep. FinCEN has to approve the compliance monitor and the monitor reports back to FinCEN. loving around here will not go well for Binance.

This is the FinCEN consent order (PDF). Look at "Undertakings", p59 to p71. FinCEN go into some detail about what they expect - though less detail than a bank would get. Read through that and just imagine crypto bozos trying to understand what any of this poo poo is. Also, lol.

When HSBC were saddled with a monitor, the "monitor" was a whole department of consultants and HSBC set up a whole department to interact with them. But HSBC (a) have a large non-fraud business (b) know how to do this poo poo.

a bit like what John Jay Ray had to do at FTX in reconstructing basic accounts from scratch

i think binance ripped people off in pieces via market crimes and not by just stealing the customer money

this settlement covers the CFTC allegations of market crimes, but not the SEC ones


quote:

"Giving a strong hint[,] such as
your account is unlocked/your account has been investigated by XXX is usually a good enough
hint of severity.”

Lmao disclosure of a SAR to anyone outside the bank/feds is a crime but they weren't filing any, so...

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