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Case study: Comprehensive examination leads to smoke and mirrors
Experience/Documenting a Crypto Exchange’s Efforts to Evade Regulatory Guidelines

Documenting a Crypto Exchange’s Efforts to Evade Regulatory Guidelines

Nardello & Co. was engaged by an international law firm on behalf of a client who believed that a crypto-related company gained a competitive advantage through illegal business practices.  

Conducting extensive research (including, inter alia, a review of corporate records, business directories, and domain registrations) in numerous jurisdictions, we were able to document links between related companies that showed that the target company had engaged in a scheme that allowed it to conduct business in certain jurisdictions without exposure to those jurisdictions’ regulatory guidelines.  

Through extensive testing on the target company’s site, we also established that the target company’s “know your customer” checks and geo-blocking policies (intended to block access to the company’s site for individuals from regulated jurisdictions) —checks and policies that the company claimed were robust— were in reality limited and ineffective and served solely as window dressing to appease regulators’ calls for tighter access controls.  

Our findings formed the basis for a referral to regulatory authorities.

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