5th December 2022 Compliance Interview with Coinify’s Money Laundering Reporting Officer Earlier last month, we had the privilege of sitting down and speaking with Coinify’s Money Laundering Reporting Officer (MLRO), Janne Schultz Rasmussen. Here, we explore and dig deeper into her role at Coinify, the importance of the MLRO role, compliance and much more. You can find Janne on LinkedIn here. What is the Role of an MLRO? The job of the MLRO is to act as the focal point within the relevant firm for the oversight of all activity relating to anti-money laundering. The primary responsibilities of an MLRO include ensuring compliance with applicable AML/CFT and KYC laws, rules, regulations, and instructions, developing end-to-end compliance programs and all AML/KYC policies, procedures, methods, tools, and so on in light of these guidelines and ensuring, monitoring and overseeing their implementation. What has brought you to the crypto industry and how did you decide to join Coinify? My curiosity for the subject started around 6 months before I joined Coinify, so around the beginning of 2022. Additionally, I had a former co-worker in the Danish FSA (Financial Supervisory Authorities) who was very keen on crypto and blockchain in general, so I also heard him discussing it in various settings. Later on, I saw an increase in media coverage concerning DeFi, blockchain, crypto and FinTechs in general. Thus, my curiosity regarding crypto and blockchain increased rapidly. As I was following the industry more closely, I saw that it was fast evolving and started to understand the ways blockchain technology can be utilised in many more industries and even in our day-to-day lives. I was fascinated by the abilities of the technologies, especially decentralisation and transparency. Shortly after, I spotted a job opportunity here, at Coinify, and could identify myself with the role immediately. The tasks associated with the role and Coinify itself, especially what they stand for, appealed to me. Could you compare your role now and previously, before you joined Coinify? Before joining Coinify, I worked for approximately 2 years at the Danish FSA (Financial Supervisory Authorities) in the office for anti-money laundering (AML) and counter-terrorist financing (CTF). To make it clear, the Danish FSA is the financial regulatory authority that is responsible for the supervision of financial institutions in relation to compliance with eg. the AML Act. During the time I worked at the Danish FSA, I went on inspection in a variety of different financial institutions, such as international banks, leasing companies, money remitters etc – all to control whether they fulfil the requirements in the AML act. Due to my background at the danish FSA, I put on my “inspection hat” during my first month at Coinify and used an approach that I would normally do during the inspection. I made sure I went through all the material that I would normally do during an inspection and asked a lot of questions on how things are done to get a full picture of how we fulfil the act in AML at Coinify. During the process, it was clear that Coinify’s Compliance mindset is deeply integrated into the company’s DNA and business model. As MLRO, can you debunk the myth that crypto goes hand in hand with criminal activities? and what can be done differently to debunk this myth? In the absence of effective regulation, cryptocurrencies can and have been used for criminal purposes. According to a report from Europol, the use of cryptocurrency as part of criminal schemes is increasing. However, the overall number and value of cryptocurrency transactions related to criminal activities still represent only a limited share of the criminal economy when compared to cash and other forms of transactions. What fascinates me about the crypto industry, among other things, is the whole blockchain technology which is the “platform” where crypto is being traded. The technology enables us to get insight into transactions and the flow of funds, which provides us with the opportunity to follow the money through the blockchain. The technology enables us to ask questions that traditional financial institutions have never been able to ask before. For example, I can see that 25% of the funds from this transaction originate from a sanctioned website or any other illicit activity. Even if the illicit activity and funds have been through a “net” of 10-20-80 transactions before it hit us, it is traceable. What do I do with this information? The illicit funds might not be linked to our customer. These are questions you have not been able to ask before. So yes, I can definitely debunk the myth at this point, because technology provides us with totally different opportunities to trace suspicious behaviour and illegal activity. That is the reason I believe crypto exchanges and blockchain technology are not just hype, we will see this technology being used more in the future. What do you hope to achieve here at Coinify in the MLRO role? A company like Coinify is a compliance-first company and compliance is in our DNA and has never been used just to ‘tick a box’. Meaning, there are cases and potential customers that we do not accept because they e.g. cannot justify the source of funds, which is mandatory at Coinify. Justifying funds is the process we go through in order to limit fraud and handle illicit funds, and we simply cannot approve clients who disagree to comply with our standards. My role is to never let the mantra – “what we did yesterday worked just fine” be a standard. The criminals probably have the most agile business model you can imagine, as they don’t have to approve budgets or wait for board meeting decisions. They adapt rapidly to where they see the slightest opportunity or loophole. And the only way to try and keep track is by constantly improving what we are doing. So in my role, I hope I can learn as much about the loopholes in order to ensure that we are on top of development in criminal activity. How has the shift been from a financial authority, essentially conducting audits, to being on the other side of the table suddenly? It has definitely been fun! One thing I liked about working at the Danish FSA was that you constantly had to understand new business models, different setups, and different systems. It provided me with different kinds of perspectives and tools for performing my job here at Coinify. I now have the opportunity to use my experiences in order to thoroughly understand one business model and one industry to its core – and to use my experience to highlight room for improvement, and actually do something about it on a day-to-day basis.