Освобождение хакера: риски для AML/KYC и проверки USDT

Target Audience

This manual is intended for private investors, P2P traders, freelancers receiving payment in cryptocurrency, and junior compliance officers.
Required Knowledge Level: A basic understanding of how blockchain works (what an address, transaction, and hash are) and the ability to use the web interfaces of block explorers and AML services.

Introduction: Why AML Analysis is the New Digital Hygiene

The case of Ilya Lichtenstein, who pleaded guilty to laundering 94,000 BTC from the Bitfinex exchange, clearly demonstrates that massive volumes of "dirty" assets circulate in the blockchain and could end up in your wallet. According to the United Nations Office on Drugs and Crime (UNODC), the USDT stablecoin on the TRON blockchain has become a key tool for illegal financial operations in Asia¹. In 2023, the volume of transactions linked to illegal activity reached $24.2 billion².

For the average user, this means that receiving funds from an unverified counterparty can lead to exchange account freezes and legal consequences. This manual is a practical guide for conducting independent Anti-Money Laundering (AML) analysis, minimizing risks, and preparing an evidence base for the source of your assets.

Assets Verification Checklist (TL;DR)

Identify the network and choose an explorer: For USDT TRC-20 (address begins with T), use Tronscan; for ERC-20 (address begins with 0x), use Etherscan.
Conduct AML analysis: Use at least two specialized AML services to obtain a Risk Score and identify links to illegal activity.
Check sanction lists: Ensure the address does not appear on the OFAC SDN list and does not have a Sanctions tag in the report.
Interpret the result: A Risk Score above 50% requires immediate action. Examine risk sources (Darknet, Mixer, Scam tags) and check for false positives (e.g., a transfer from an exchange hot wallet).
In case of high risk — act with caution: Consider isolating funds only after consulting with a compliance specialist or a lawyer. Do not mix risky assets with others. Document every operation and keep in mind that moving funds might be interpreted as an attempt to hide their origin.
Communicate with the exchange: If the funds are already on an exchange or you plan to deposit them there, proactively contact support, providing all collected documentation.
Keep evidence: Save full verification reports in an immutable format (PDF) for at least 5 years (or longer, depending on your jurisdiction's requirements).

Differences in USDT Implementations: TRC-20, ERC-20, and Others

Before starting the analysis, it is important to understand which version of USDT you are working with.

USDT TRC-20: Operates on the TRON network. Addresses start with the letter T. Use the Tronscan explorer for analysis. This is the most popular version for retail transactions due to low fees.
USDT ERC-20: Operates on the Ethereum network. Addresses start with 0x. Use Etherscan for analysis.
Other Networks: USDT also exists on Polygon, Solana, and other blockchains. Each network requires its own explorer (e.g., Polygonscan, Solscan).

Transfers between networks via bridges complicate tracing, as the history of funds breaks on one blockchain and continues on another. In this case, analysis must be conducted on both ends of the bridge: checking the address from which funds entered the bridge contract and the address from which they exited on the target network.

Step-by-Step USDT Verification Instructions

Step 1: Examine Transaction History in a Block Explorer

This is a basic and free way to identify obvious "red flags."

Copy the wallet address and paste it into the search bar of the corresponding explorer (Tronscan or Etherscan).
Examine the Token Transfers and Transactions tabs.
What to look for:
- Sources of Funds: The presence of labels for known exchanges (Binance, Kraken) among senders is a good sign. Addresses without labels and with high turnover require close attention.
- Transaction Patterns: Numerous small incoming transfers from unrelated addresses followed by rapid consolidation and withdrawal of the entire amount is a sign of structuring or mixer usage.
- Interaction with Contracts: Check if the wallet has interacted with addresses labeled as Tornado Cash or other high-risk services.

Step 2: Use Specialized AML Services

Manual analysis does not reveal hidden connections. Professional tools are necessary for deep verification.

Tools: GetBlock, AMLBot, Btrace (available for individual checks), Chainalysis, Elliptic (corporate solutions).
How to choose a service:
- Reputation: Choose well-known services with transparent methodologies.
- Confidentiality: Clarify the service's policy regarding the data you verify.
- Risks: Remember that any tool may contain errors or delays in database updates. Therefore, it is recommended to use at least two different services for cross-verification.

Step 3: Learn to Read an AML Report

Risk Score: A percentage showing the portion of funds in the wallet linked to risky sources.
- 0–15% (Green Zone): Low risk. Funds are considered "clean."
- 15–50% (Yellow Zone): Medium risk. Requires source analysis. Often arises from indirect links to risky assets through large services (e.g., exchanges).
- >50% (Red Zone): High risk. Direct interaction with such an address will highly likely lead to a freeze on a centralized platform.

Note: These threshold values are empirical guidelines based on industry practice. They may vary between services and the requirements of a specific jurisdiction or exchange. Always use them as a starting point for analysis rather than a legal rule.

Risk Breakdown / Tags: A chart or list showing which categories the wallet is associated with.
- Safe Tags: Exchange, Mining Pool, DeFi, Wallet Service.
- Dangerous Tags: Darknet Market, Scam, Ransomware, Sanctions, Mixer.

Step 4: Document Every Check

Saving evidence is your main argument in disputes and proof of due diligence.

What you need to save:

Full PDF report from the AML service (export it rather than taking a screenshot).
File hash of the report (optional): To further prove the document's immutability, you can calculate and save its hash (e.g., SHA-256).
Text file with key information:
- The address being verified.
- Date and time of the check (in UTC format).
- AML services used and their versions.
- Result: Risk Score, primary risk sources.
- Related transaction hash (tx-hash).

Storage Period: It is recommended to store this data for at least 5 years, but always check your jurisdiction's requirements as they may be stricter.

Practical Examples: False Positives and Real Risks

Case 1: False Positive — Link to an Exchange Hot Wallet

Situation: You receive 1,000 USDT from an address whose AML analysis shows a Risk Score of 20%. The risk sources indicate a link to a High-Risk Exchange.
Analysis: A more detailed study of the report reveals that 99% of the funds on the sender's address came from the hot wallet of a major exchange (e.g., Binance). The exchange itself has a Risk Score of 15% due to its massive transaction volume, which inevitably includes some risky ones.
Conclusion: This is a false positive. The risk is negligible as it is inherited from a large legitimate service rather than a direct link to illegal activity.

Case 2: Real Risk — Funds from a Mixer

Situation: You receive 5,000 USDT from an address with a Risk Score of 85%. Risk sources indicate Mixer (80%) and Darknet (5%).
Analysis: The block explorer shows the address received numerous small transactions from various addresses with no history, and the funds were consolidated before being sent to you. The AML report confirms these funds passed through a mixer (e.g., Tornado Cash), and a portion has a direct link to a darknet market.
Conclusion: This is a high risk. Accepting these funds will almost certainly lead to problems.

Action Plan for High Risk (Risk Score > 50%)

Do not panic and do not try to "clean" the funds. Using mixers or shady exchangers will be viewed as an intentional attempt at money laundering and will worsen the situation.
Consult a specialist. Before taking any action with risky assets, contact a lawyer specializing in digital assets or a compliance officer. Further steps should be coordinated with them.
Consider asset isolation. The goal of isolation is to separate risky assets from clean ones to prevent "contamination" of your entire capital and to ensure transparent reporting.
- Create a new, previously unused wallet.
- If, after consulting with a lawyer, a decision is made to move the funds, transfer the entire amount of risky assets in a single transaction. This preserves a clear history of the funds' movement.
- Document this transaction: save its hash, date, and time.
Contact exchange support (if applicable). If the funds are on a centralized platform, proactively reach out to support.

Support Email Template:

Subject: Proactive Compliance Risk Inquiry — [Your User ID]

Dear [Exchange Name] Compliance Department,

As part of my due diligence procedure, I conducted an AML analysis of the sender address \[sender address] prior to receiving funds. The results showed a high risk level ([specify percentage]). I am prepared to provide all supporting documents for your analysis and am following the recommendations of my legal counsel. Please provide instructions on further actions on my part.

Attached Documents:

PDF AML analysis report from [Service Name].

Transaction hash of the received funds: \[tx-hash].

Sincerely, [Your Name]

Legal and Regulatory Aspects: Key Jurisdictions

AML/CFT (Anti-Money Laundering and Countering the Financing of Terrorism) requirements vary significantly by country.

USA: Regulated by FinCEN (Financial Crimes Enforcement Network) based on the Bank Secrecy Act. Companies working with cryptocurrency (exchanges, platforms) must register as Money Services Businesses (MSB) and file Suspicious Activity Reports (SARs).
European Union: Regulated by EU-wide directives (e.g., 5th and 6th AMLD), implemented into the national laws of member states. Virtual Asset Service Providers (VASPs) are "obligated entities" and must conduct KYC/AML procedures and report suspicious operations to their national Financial Intelligence Units (FIU).
General Recommendations: Regardless of jurisdiction, the obligation to report suspicious transactions may apply not only to companies but also to individuals in certain situations. Always research local legislation. Failure to comply with these requirements may lead to liability.

Conclusion

Proactive AML analysis is not an option but a mandatory element of digital hygiene for every cryptocurrency user. Regular verification, thorough documentation, and calculated actions based on risk analysis are the best investments in the security of your digital assets. This manual is for informational purposes and does not constitute legal advice.

Sources and Useful Materials

Organization: United Nations Office on Drugs and Crime (UNODC)
Year: 2024
Title: Casinos and Cryptocurrency: Major Drivers of Money Laundering, Underground Banking, and Cyberfraud in East and Southeast Asia.
URL:
https://www.unodc.org/roseap/en/2024/01/casinos-and-cryptocurrency_-major-drivers-of-money-laundering—underground-banking—and-cyberfraud-in-east-and-southeast-asia/story.html
Access Date: 10/17/2024
Organization: Chainalysis
Year: 2024
Title: The 2024 Crypto Crime Report.
URL:
https://www.chainalysis.com/resource/the-2024-crypto-crime-report/
Access Date: 10/17/2024