Criminals employ a broad range of blockchain-based tokens (e.g., DeFi tokens, governance tokens, or stablecoins) to create intertwined transactional layers that obscure illicit fund flows. By rapidly converting proceeds among token formats or using cross-chain bridging protocols, they break address continuity and hamper detection. Decentralized exchanges and minimal-KYC platforms add further complexity by allowing pseudonymous swaps, making it difficult for authorities to link criminal proceeds to specific addresses. Criminals also exploit stablecoin ecosystems for easier cross-border transfers, then avoid freezes by quickly swapping into other tokens or bridging to alternate networks. Overall, these repeated conversions and multi-network transactions obscure origins and challenge investigators in decentralized environments where regulatory oversight is limited.
Virtual Token
Digital Token
Crypto Token
Virtual Token Utilization
Tactics
Criminals repeatedly convert illicit proceeds among various blockchain tokens and networks, leveraging smart contracts and cross-chain bridging to create a convoluted transactional trail that distances funds from their criminal origin, complicating investigative efforts.
Risks
Criminals exploit the inherent qualities of virtual tokens (stablecoins, DeFi tokens, governance tokens, etc.) to rapidly convert proceeds into multiple token formats, fragment transaction histories, and hamper detection. The ability to create and trade tokens with minimal regulation is the central operational vulnerability, making this the primary risk for this technique.
Decentralized and minimal-KYC platforms (e.g., P2P exchanges, DeFi services, cross-chain bridging) enable pseudonymous token swaps and cross-border transfers, allowing criminals to bypass traditional oversight and complicate AML detection efforts.
Indicators
Use of complex token transfer chains, including intermediary wallets and mixing services, to fragment and conceal fund trails.
High-frequency token transfers across multiple blockchain addresses without a discernible economic rationale, indicating layering or obfuscation.
Large-volume or high-value virtual token transactions that significantly deviate from a customer's usual transaction patterns.
Rapid conversions of virtual tokens into other cryptocurrencies or fiat with minimal holding periods, indicative of layering or obfuscation.
Transactional usage of decentralized exchanges with limited or no KYC verification, where tokens are rapidly traded in and out to exploit anonymity.
Multiple blockchain wallet addresses associated with a single customer lacking verifiable identity documentation.
Customer reluctance or failure to disclose a credible source of funds or business purpose for virtual token transactions.
Sudden shifts in token usage behavior—e.g., from conventional cryptocurrencies to rapid virtual token trading—without a clear business or personal rationale, indicating potential layering.
Engaging in token transactions involving governance rights or digital collectibles in a manner inconsistent with the customer's established profile, indicating potential obfuscation.
Frequent small-value token transactions that cumulatively reach substantial sums without an apparent economic rationale, indicating structuring or threshold avoidance.
Inconsistencies and rapid changes in designated wallet addresses linked to a customer for token transactions, indicating potential evasion of traceability.
Very short intervals between token acquisition and subsequent transfers to other wallets or exchanges, consistent with rapid layering or obfuscation.
Frequent or repeated cross-chain bridging among multiple blockchain networks in short intervals, lacking a legitimate business or personal rationale.
Rapid stablecoin usage for cross-border transactions, quickly swapped into other tokens or bridged to alternate networks to evade possible freezes or oversight.
Data Sources
Provides detailed logs from centralized or semi-regulated cryptocurrency exchanges and other VASPs, including user account information, deposit and withdrawal records, trading histories, and KYC data. This helps link on-chain addresses to real customers when available, detect suspiciously frequent token conversions or bridging activities, and identify layering attempts across both decentralized and regulated platforms.
- Includes verified identity data, beneficial ownership details, and risk assessments for customers.
- Allows comparison of declared wallet addresses and source of funds against actual usage.
- Identifies potential mismatches, undisclosed addresses, or suspicious multi-wallet patterns that may indicate layered token transactions.
- Provides on-chain transaction details, including transaction IDs, timestamps, addresses, token types, and amounts from public ledgers, along with related analytics.
- Enables the detection of rapid cross-chain token movements, multiple address hops, and bridging activities.
- Facilitates the identification of layering or obfuscation attempts by analyzing frequent conversions, short holding periods, and irregular token flows.
- Covers cross-border financial flows, associated institutions, currencies, and settlement processes.
- Enables correlation of stablecoin or token movements with foreign transactions, helping detect abrupt cross-border layering or swift swaps intended to evade oversight.
- Supports identification of uncharacteristic international fund transfers that align with virtual token obfuscation strategies.
Mitigations
Require customers to declare all relevant wallet addresses, bridging protocols, and intended token usage. When high-volume or rapid bridging is observed, verify legitimate ownership and the source of funds (e.g., business records, contracts). This reduces anonymity in decentralized platforms by establishing a transparent link between customers and their token activities.
Implement specialized analytics to flag short holding periods, frequent token conversions, and cross-border stablecoin flows lacking a clear business rationale. Focus on repeated bridging activity and ephemeral wallet usage, triggering alerts for further investigation when patterns suggest layering or obfuscation techniques.
Employ dedicated blockchain analytics to track token movements across different networks, detecting repeated bridging, layering patterns, and high-volume or rapid-fire swaps. By correlating wallet activity across multiple chains, institutions can pinpoint addresses coordinating pseudonymous transactions for illicit fund flows.
Train compliance and frontline teams to recognize red flags unique to digital token schemes, such as rapid stablecoin swaps, cross-chain bridging within minutes, or complex token layering without a legitimate business rationale. Provide updated case studies on newly identified blockchain-based laundering methods.
Assign higher risk ratings to customers conducting frequent cross-chain bridging, high-volume stablecoin transactions, or complex multi-token layering. Apply enhanced reviews and stricter monitoring thresholds to these profiles, ensuring that unusual or opaque token flows prompt rapid compliance intervention.
Check wallet addresses and bridging platforms against open-source data, adverse media, and public advisories. Investigate entities tied to known mixers or sanctioned sites, ensuring suspicious cross-chain bridges are flagged or escalated for further review. This augments due diligence by exposing illicit connections often hidden in decentralized environments.
Limit or block high-risk decentralized bridging channels and token transactions associated with minimal KYC platforms. Freeze or deny transfers involving wallets flagged for repeated obfuscation or layering activities. These controls deter criminals from exploiting unregulated token swaps and cross-chain mechanisms at scale.
Regularly review customer profiles and transaction behaviors to identify new wallet addresses, sudden escalations in bridging activity, or unexplained shifts to high-risk tokens. Immediately subject these changes to further scrutiny to ensure emerging obfuscation tactics are detected promptly.
Instruments
- Criminals exploit a wide range of virtual tokens to rapidly convert illicit proceeds among multiple formats, breaking transaction continuity.
- Decentralized exchanges and cross-chain protocols allow swift swaps and bridging that hinder law enforcement's attempts to trace fund flows.
- The pseudonymous nature of token transactions, coupled with limited regulatory oversight, makes it challenging to link addresses to real identities.
- Criminals create multiple self-hosted and pseudonymous wallets to fragment illicit funds across diverse addresses, making it difficult to trace origins and ultimate beneficiaries.
- Each wallet can store various blockchain tokens, enabling rapid, repeated conversions and cross-chain transfers that break transaction continuity.
- The minimal KYC requirements for self-hosted wallets reduce transparency and hamper investigators’ efforts to identify real owners.
- Criminals leverage stablecoins for cross-border transfers, reducing price volatility that might otherwise draw attention.
- By quickly swapping these stablecoins into other tokens or bridging them to alternate blockchain networks, they evade freezes or enhanced scrutiny.
- Minimal or no KYC on certain platforms allows illicit proceeds to be moved under the veneer of ordinary stablecoin transactions.
- Criminals layer illicit proceeds by moving them into governance tokens, presenting these transfers as legitimate participation in decentralized protocol governance.
- The added voting utility can mask large or frequent token transfers under the guise of platform engagement, complicating compliance monitoring.
- Clandestine swaps and sales on minimal-KYC or decentralized exchanges obscure beneficiary identities, hindering law enforcement tracing.
- Criminals rapidly swap illicit funds into utility tokens on decentralized platforms, dispersing transactions across multiple protocols.
- These tokens often operate under low regulatory oversight, allowing pseudonymous exchanges that distance the funds from their criminal source.
- By fractionating funds into different utility tokens and ecosystems, offenders create a tangled audit trail that investigators find difficult to untangle.
- Criminals deliberately wrap and unwrap tokens to shift value across blockchains that do not natively support the original asset.
- Each conversion interrupts transaction history, scattering records among multiple ledgers and making tracing more complex.
- Rapid cross-chain bridging using wrapped tokens complicates detection and enables criminals to bypass potential monitoring or freezes on a single network.
Service & Products
- Facilitate pseudonymous token swaps, lending, and borrowing with limited or no central oversight, undermining KYC efforts.
- Smart contracts and decentralized platforms enable criminals to layer illicit proceeds without clear identifiable parties.
- Enable direct user-to-user trades often without robust KYC, complicating AML oversight.
- Allow criminals to fragment transactions into smaller amounts and rapidly swap tokens under pseudonymous profiles, hindering detection of the original source of funds.
- Provides near-instant conversions between various tokens without requiring extensive user vetting.
- Criminals repeatedly swap stablecoins and other tokens to break transactional links and hinder investigations.
- Criminals exploit minimal or lax KYC procedures on certain platforms to convert illicit proceeds into various tokens and back, impeding law enforcement tracking.
- Rapid stablecoin conversions facilitate cross-border transfers with limited oversight, further obscuring the source of funds.
- Criminals transfer tokens among multiple blockchain networks, breaking transaction continuity and obscuring fund flows.
- Repeated bridging confuses investigators by scattering transaction records across different chains, reducing traceability.
Actors
Professional money launderers employ virtual tokens for layering by:
- Rapidly converting illicit proceeds among various tokens (including stablecoins, governance tokens, or DeFi tokens) to obscure the original source of funds.
- Utilizing cross-chain bridging protocols, scattering transaction records across multiple blockchains.
- Exploiting minimal- or no-KYC platforms, preventing clear identification of the ultimate beneficial owner.
Criminals exploit these service providers by:
- Initiating pseudonymous token swaps and conversions under insufficient KYC procedures.
- Rapidly bridging stablecoins across different blockchain networks to evade potential freezes or scrutiny.
- Creating intertwined token transactions that hinder traceback, complicating investigations by financial institutions.
References
Royal United Services Institute for Defence and Security Studies. (2024). Euro SIFMANet: European Sanctions and Illicit Finance Monitoring and Analysis Network Virtual Asset Sanctions Roundtable Report. Royal United Services Institute for Defence and Security Studies.https://www.rusi.org/explore-our-research/publications/conference-reports/euro-sifmanet-virtual-asset-sanctions-roundtable-report
Akartuna, E. A., Madelin, T. (2022). The state of cross-chain crime: Countering the new age of crypto crime and money laundering in a cross-chain world. Elliptic. https://www.elliptic.co/resources/state-of-cross-chain-crime-report
Zubic, E. (2024). Chain Hopping in Crypto: How to Track Cross-Blockchain Fund Movement. OSINT Ambition. https://publication.osintambition.org/chain-hopping-in-crypto-how-to-track-cross-blockchain-fund-movement-138da36dd6e9