Risky Exchange
An exchange with documented AML weaknesses, illicit exposure or enforcement concerns; KYC and licensing duties vary by jurisdiction.
What does it mean?
High-risk category group
An exchange with documented AML weaknesses, illicit exposure or enforcement concerns; KYC and licensing duties vary by jurisdiction.
The 14 categories in the AML4Tracker risk methodology, explained with documented examples. The groups below describe that taxonomy; they are not universal legal classifications or the numerical bands of a live report. Availability depends on the report and data provider.
How is this concept used?
A finding should explain the documented concern: missing required customer checks, AML/CFT proceedings, a missing required licence or non-compliance with a lawful authority request. The applicable jurisdiction and case status matter.
Documented examples
Documented example
Bitzlato: guilty plea (2023)
On 6 December 2023, the U.S. DOJ announced that Bitzlato founder Anatoly Legkodymov pleaded guilty in Brooklyn to operating an unlicensed money transmitting business. The notice described deficient customer identification controls; this dated case is not a current assessment of every exchange user.
Source publication: · Source checked:
Documented example
BTC-e: FinCEN civil action (2017)
In its 27 July 2017 release, FinCEN announced a civil penalty against BTC-e for violations of U.S. AML laws and described deficient customer information controls. This was a U.S. civil enforcement action, not a criminal judgment against every customer.
Source publication: · Source checked:
Connection to a wallet report
Check the exchange identity, jurisdiction, dated authority source and whether an issue is alleged or finally established. A customer transfer does not itself determine that customer’s conduct.
A common misconception
A missing licence matters only where that licence is required; an allegation is not a final legal finding.
Why it matters
Reported issues may include missing required KYC, documented AML/CFT proceedings, absence of a required licence or failure to comply with a lawful authority request. Check the jurisdiction and distinguish an allegation from a final finding.
Related reading
Put the explanation in context
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