Deposit Methods - Origin of Funds

Identification of Sender - Incoming National Currency Value

PayPal type account vs Bitcoin account (wallet)

Linked/Verified
Bank Account
Identity on bank act. matches the
identity on PayPal account

Coinstar Kiosk
Coin & Note Deposits
Enrolled & verified accounts only
Small maximum monthly limits

Cash Funds
Via MoneyPak

PayPal
Account

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Funds entering a PayPal account

Identity of depositor is verified

Maximum limits on monthly deposits
Product only sold by licensed MSB

(PayPal is being used here as an example of a licensed and regulated online payment account.)
Deposits made through a bank account are highly regulated. Banks will only conduct transactions with people
holding accounts and those account holders must provide a significant amount of personal information when
they open the account.
MoneyPak makes it possible to deposit cash funds into PayPal without requiring a credit card or bank account.
Most MoneyPak retailers have a maximum deposit limit of $500 - $1000. This prepaid product is sold at
thousands of locations nationwide. Usage of this service is subject to identity verification and other controls.
PayPal requires the depositor to provide a name, address, date of birth and Social Security number in order for
Green Dot to verify an identity before using the MoneyPak to add cash funds to a PayPal account. Green Dot
will collect, verify and record this information on behalf of PayPal. This service is being provided by a
registered Money Services Business. Once a customer has been verified, there is a maximum MoneyPak
deposit of $4,000 a month. Money transferred from MoneyPak to PayPal appears immediately.
It is possible to deposit cash funds into a PayPal account through a Coinstar kiosk. PayPal on Coinstar allows
account holders to easily add coins and paper money. Before a PayPal customer can complete a PayPal
transaction at a Coinstar kiosk, that account must be enrolled and the account information must be verified.
The limit for adding coins to an account is $475 is the maximum per calendar month. The limit on paper notes
is $500 per account per calendar month.
Value entering a PayPal account originates with a verified party and a regulated bank product. The deposit
process creates a substantial legal source of funds record. There are maximum limits of these deposit
methods and attempts at higher than average deposits are met with Money Service Businesses reporting
requirements. At any future time, if an account or series of transactions is deemed suspicious or illegal, the
funds and the account owner are highly traceable.

CARL- panama@cryptoheaven.com

Deposit Methods
Apple Store Gift Card Code
Alipay
AstroPay
Amazon Gift Card Code
BPAY Bill Payment
Cash
Cash Deposit
Cash by mail
CashU
Chase Quickpay
Cashier's check
Dwolla
EgoPay
Gift Card Code
Interac e-transfer
International Wire (SWIFT)
OKPay
Payza
Pingit
PostePay
M-PESA Kenya (Safaricom)
M-PESA Tanzania (Vodacom)
MobilePay
Moneygram
MoneyPak
Neteller
NetSpend Reload Pack
National bank transfer
PaySafeCard
Paypal
Perfect Money
Paym
Postal order
QIWI
Transfers with specific bank
Tigo-Pesa Tanzania
Telegramatic Order
Transferwise
SEPA (EU) bank transfer
Skrill
Superflash
Steam Gift Card Code
SolidTrustPay
Swish
Starbucks Gift Card Code
Ukash
Vanilla
Venmo
WebMoney
Walmart Gift Card Code
Western Union

Value entering a Bitcoin wallet often originates from an unknown and

untraceable source. Including cash, there are dozens of nonconventional untraceable methods for depositing value into a Bitcoin
wallet. There are no maximum limits on these deposits and very often
no verifiable "source of funds" which would leave a traceable record
of ownership. At a later time, if wallet activity, such as a deposit or a
transaction is deemed suspicious or illegal, the origin of the Bitcoin
funds and the owner of the wallet are often impossible to identify and
trace. This makes prosecuting a financial crime difficult and often
impossible.
The looming issue, for both State and Federal regulators, stems from
the number and variety of Internet accessible digital currency
products which are now freely exchangeable with Bitcoin and other
virtual currencies. It's projected that upwards of 1000 or more new
digital currency products, both centralized and decentralized, will
become available to Internet users around the globe in the next few
years. Many of these new digital tools will be specifically created to
protect the user from being identified and to anonymously circulate
value as a digital currency product from user to user without leaving a
traceable transaction record.

Bitcoin
Wallet

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Funds entering a Bitcoin Wallet

Funds entering a Bitcoin wallet can originate from someone other

than the wallet owner (Third party). By using cash deposits or any
one of the many other non-conventional digital currency products,
any third party can easily make a deposit to another user's Bitcoin
wallet.
Also, there are no maximum limits on deposits to a Bitcoin wallet
and no reporting requirements for large transactions or exchanges.
A deposit of $1,000,000 worth of Bitcoin triggers no reporting
requirement such as a SAR or CTR. Even the movement of
$1,000,000 from the United States across the border into a foreign
country requires no reporting such as a CMIR.
Many of the financial companies offering these digital currency
products have terms of service which do not permit the exchange of
the products for another digital currency or virtual currency (currency
exchange). These exchanges take place without the knowledge or
consent of the issuer.
However, some of the more popular and more transacted digital
currency products allow for the exchange of a digital currency
product for another digital currency without restriction.

CARL- panama@cryptoheaven.com

Payment received by PayPal merchant & credit card processor

vs
Payment received by Bitcoin payment processor
(SAAS Bitcoin Merchant Service, etc.)
This is an example of a MSB/MT regulated Internet payment
Both ends of the transaction are regulate accounts.
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PayPal
Account

(verified sender)

PayPal
Merchant

(verified receiver)

National $
Currency
Payment
(verified bank account)

This is an example of a regulated credit card payment

Both ends of the transaction are highly regulated accounts.

Credit Card
Issuer

(verified sender)

Merchant
Acquirer
(verified receiver)

National $
Currency
Payment
(verified bank account)

This is an example of an unregulated Bitcoin payment. A Bitcoin wallet, which offers no verifiable
source of funds or legal owner, delivers a payment to the Bitcoin payment processor.
Only the payment processor wallet is verified. After the Bitcoin is accepted, the payment
processor executes an additional exchange transaction from Bitcoin into national currency.
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Bitcoin
Wallet
(unknown sender)
(unverified source)

Bitcoin
Payment
Processor
(verified receiver)

This is regarded as a regulated exchange

transaction. It may not be a verified payment moving
from bank to bank. This Bitcoin payment processor
is accepting an alternative currency payment from
an unknown and untraceable source and
exchanging into a national currency bank payment.
Here is one point-of-risk.

National $
Currency
Payment
(verified bank account)
This additional exchange and
subsequent transmission of
value is typically regulated by
state money transmission laws
and also governed by federal
regulations.
CARL- panama@cryptoheaven.com