The complaint filed by the CFTC is unexpected and disappointing as we have been working collaboratively with the CFTC for more than two years. Nevertheless, we intend to continue to collaborate with regulators in the US and around the world. The best path forward is to protect our users and to collaborate with regulators to develop a clear, thoughtful regulatory regime.
We have made significant investments over the past two years to ensure we do not have US users active on our platform. During that period, we went from approximately 100 people in our compliance team to around 750 core and supporting compliance personnel today, including almost 80 personnel with prior law enforcement or regulatory agency experience and approximately 260 personnel with professional certificates in compliance.
We have spent an additional $80,000,000 on external partners, including KYC vendors, transaction monitoring, market surveillance and investigative tools that support our compliance programs.
Consistent with regulatory expectations globally, we have implemented a robust “three lines of defense” approach to risk and compliance, which includes, but is not limited, to:
Ensuring mandatory KYC for all users worldwide
Maintaining country blocks for anyone who is a resident of the US
Blocking anyone who is identified as a US citizen regardless of where they live in the world
Blocking for any devices using a US cellular provider
Blocking log-ins from any US IP address
Preventing deposits and withdrawals from US banks for credit cards
