Custodial Mixers

Custodial mixers are centralized cryptocurrency services that receive user deposits into an operator-controlled wallet, commingle them in a large pool, and repay users with outputs ostensibly unrelated to their original inputs. This arrangement breaks the direct link between deposit and withdrawal addresses, thereby obscuring fund provenance and ownership. Unlike decentralized (non-custodial) mixers, all assets are held under a single operator’s control, which introduces both a single point of failure and a dependency on the operator’s honesty and security practices. Criminals favor custodial mixers for rapid and large-scale laundering, capitalizing on minimal compliance oversight and exploiting the service’s capacity to blend illicit funds with legitimate cryptocurrency flows. Many custodial mixers are reported to ignore regulatory obligations entirely, further impeding investigators’ ability to trace transactions. In practice, illicit actors can deposit tainted assets into these services, receive “clean” withdrawals, and repeat the process for additional layering, confounding efforts to place the funds back to their unlawful source.

[
Code
T0003.001
]
[
Name
Custodial Mixers
]
[
Version
1.0
]
[
Parent Technique
]
[
Tactics
]
[
Risk
Product Risk, Jurisdictional Risk
]
[
Created
2025-02-06
]
[
Modified
2025-04-02
]

Tactics

ML.TA0007
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|

Custodial mixers combine user deposits in an operator-controlled wallet and redistribute them as unrelated outputs. This process introduces multiple transaction layers that conceal illicit proceeds and complicate investigative tracing efforts.

Risks

RS0002
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Product Risk
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Custodial mixers function as a specialized service that centralizes user deposits under a single operator, providing anonymity and bypassing standard AML scrutiny. Criminals exploit the product's inherent commingling and opaque withdrawal process to obscure the provenance of funds and evade detection.

RS0004
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Jurisdictional Risk
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Many custodial mixers operate in jurisdictions with minimal or weak AML/CFT enforcement, allowing criminal actors to exploit lax regulatory obligations and bypass compliance measures on a large scale.

Indicators

IND01136
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Funds are transferred to an address identified as controlled by a custodial mixer operator.

IND01137
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Customer receives cryptocurrency from a different address than the one used for the deposit to the custodial mixer, indicating separation of funds.

IND01138
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Multiple small deposits to the custodial mixer, followed by consolidated withdrawals, indicating layering of funds.

IND01139
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Funds are deposited into a custodial mixer and withdrawn in quick succession, reflecting minimal holding periods.

IND01140
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A client with historically limited cryptocurrency activity suddenly begins using custodial mixer services.

IND01141
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Frequent use of custodial mixers with multiple unrelated withdrawal addresses in a short timeframe.

IND01142
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Discrepancies between the customer’s declared wallet details and the actual addresses used for custodial mixer deposits or withdrawals.

IND01143
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Anomalous discrepancies between amounts deposited and withdrawn through the custodial mixer, not aligning with typical service fees or exchange rates.

IND01144
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Frequent or high-value transactions directed to custodial mixers known to operate in jurisdictions with minimal AML/CFT oversight.

Data Sources

  • Consolidates AML/CFT risk profiles for countries and regions, highlighting areas with weak regulatory controls.
  • Supports risk-based monitoring by flagging transactions to custodial mixers in high-risk jurisdictions, aligning with suspicions of minimal AML oversight.
  • Aggregates publicly available information on custodial mixer operators, including location and regulatory status.
  • Assists in identifying mixers operating in jurisdictions with minimal AML oversight or those flagged for illicit activities, thereby supporting enhanced due diligence.
  • Provides comprehensive records of deposits, withdrawals, timestamps, amounts, and counterparties.
  • Enables detection of patterns such as multiple small deposits, rapid withdrawals, and mismatches between deposit and withdrawal addresses—key indicators of custodial mixer usage.
  • Captures detailed logs from cryptocurrency exchanges and other VASPs, including wallet addresses, transaction histories, and user activity.
  • Enables reviewing user interactions with known custodial mixer addresses or identifying patterns indicative of layering and rapid turnover via mixer services.
  • Contains verified customer identities, historical transactional behaviors, and risk assessments.
  • Helps detect sudden changes in cryptocurrency usage (e.g., new mixer transactions) or discrepancies between declared and actual wallet addresses, supporting investigations into suspicious mixer involvement.
  • Provides on-chain transaction information, including sender and receiver addresses, timestamps, and amounts.
  • Enables direct tracing of funds to mixer-associated addresses, detection of address separation (layering), rapid turnover events, and discrepancies between deposit and withdrawal amounts.

Mitigations

Apply Enhanced Due Diligence (EDD) protocols to customers or counterparties who repeatedly use custodial mixers. Verify the source of crypto assets, corroborate the stated purpose of transactions, and challenge the legitimacy of recipient addresses. This deeper scrutiny exposes illicit layering attempts aimed at disguising beneficial ownership.

Implement specialized detection rules for transactions to or from addresses associated with known custodial mixers, focusing on patterns such as multiple small deposits, consolidated withdrawals, or rapid pass-throughs. By flagging these flows in real time, institutions can promptly investigate layering attempts and reduce exposure to illicitly laundered funds.

Regularly screen custodial mixer operators and their cryptocurrency addresses against applicable sanctions and regulatory advisories. If mixers are designated or blacklisted, immediately block or freeze related transactions to prevent inadvertent facilitation of sanctioned entities.

Use advanced blockchain analytics to identify addresses flagged as custodial mixers, track fund flows through aggregator wallets, and detect short deposit-to-withdrawal intervals. This enables visibility into repeated mixing cycles, revealing layering patterns that obscure the original fund provenance.

Provide specialized training on identifying custodial mixer usage, including short deposit-to-withdraw intervals, large-scale commingling, and patterns indicating repeated layering attempts. Equip staff to recognize and escalate these red flags promptly in line with institutional policies.

Leverage open-source intelligence and external data (e.g., blockchain explorer flags, industry advisories) to identify mixers that openly advertise minimal or no compliance. Cross-check deposit and withdrawal addresses discovered via OSINT to reveal undisclosed relationships with custodial mixers, exposing additional layering attempts.

Restrict or block transactions linked to custodial mixers known to operate without AML controls or located in jurisdictions with minimal oversight. This measure prevents direct engagement with high-risk mixers, limiting opportunities for criminals to layer funds undetected.

Instruments

  • Criminals deposit illicit cryptocurrency into the custodial mixer's central wallet, pooling their funds with other users' deposits in a single operator-controlled address.
  • The mixer subsequently disburses withdrawals from addresses unrelated to the original deposit, breaking the direct transaction trail and obscuring the source of funds.
  • Commingling and redistributing funds in this manner hinders investigators' ability to trace or attribute suspicious activity, creating multiple transaction layers.
  • Minimal or absent KYC measures allow large, rapid inflows and outflows, concealing ultimate beneficiaries and complicating financial institutions' due diligence efforts.

Actors

Illicit operators, including professional money launderers and organized crime groups, deposit tainted cryptocurrency into custodial mixers, receive seemingly unrelated withdrawals, and repeat the process. This layering obscures the unlawful origin of the funds and complicates financial institutions' efforts to identify or attribute the transactions to their underlying criminal activity.

Custodial mixer operators manage a single wallet that combines user deposits and redistributes withdrawals to new addresses, breaking the direct link between inputs and outputs. Their centralized custody of funds and minimal (or absent) compliance measures hinder financial institutions and investigators from tracing illicit proceeds, as all transactions appear to originate from the same broad pool rather than from individual users.

References

  1. O'Neill, A. (2024). Upholding North Korea Sanctions in the Age of Decentralised Finance. Royal United Services Institute for Defence and Security Studies.https://static.rusi.org/north-korea-sanctions-and-cryptomixers-op-march-2024.pdf

  2. Kenneth, S.(2023) The Satoshi Laundromat: A Review on the Money Laundering Open Door of Bitcoin Mixers. Journal of Financial Crime, Vol. 31 No. 2, pp. 416-426, 2024 DOI: 10.1108/JFC-11-2022-0269, Available at SSRN: https://ssrn.com/abstract=4281625 or http://dx.doi.org/10.2139/ssrn.4281625