Case Study: Ensuring Regulatory Compliance for CoinWorks Inc Bitcoin ATM Network

Case Study: Regulatory Compliance for CoinWorks Inc Bitcoin ATM Network

In recent years, the rise of cryptocurrencies has revolutionized the financial landscape, introducing new opportunities and challenges for businesses worldwide.

Among the innovative ventures within this realm are Bitcoin ATMs, which allow users to buy and sell cryptocurrencies conveniently.

However, the operation of Bitcoin ATMs comes with regulatory complexities, particularly concerning compliance with anti-money laundering (AML) and know your customer (KYC) regulations.

In this case study, we explore how CoinWorks Inc., a money service business (MSB) registered with the Financial Crimes Enforcement Network (FinCEN), navigates the regulatory landscape to ensure compliance with AML and KYC requirements in its Bitcoin ATM operations.

Disclaimer: This case study is for informational purposes only and does not constitute legal advice. Please consult with an attorney regarding your specific compliance needs.


CoinWorks Inc. is a leading provider of Bitcoin ATM services, operating a network of ATMs across various locations. As an MSB, CoinWorks is subject to strict regulatory oversight aimed at preventing illicit financial activities such as money laundering and terrorist financing. Compliance with AML and KYC regulations is not only a legal requirement for CoinWorks but also essential for maintaining the trust of customers and regulators alike.

What is a Bitcoin ATM?

A bitcoin ATM is a machine that allows customers to buy or sell bitcoin using cash. It’s a kiosk terminal similar to normal bank ATMs. Operators of such machines place them in locations such as gas stations and shopping malls for easy access.

The process of buying bitcoin through a bitcoin ATM often requires different levels of verification to comply with local laws and regulations.

Challenges Faced by CoinWorks

The Bitcoin ATM industry is constantly at the battlefront with adversaries on many levels. Preventing fraud and scams, working with banking partners and explaining the business to regulators – it all challenges operators to stay calm and professional.

The most critical aspect of the business is certainly the legal aspect. Operating Bitcoin ATMs presents several unique challenges in terms of regulatory compliance:

  1. Transaction Monitoring: With a high volume of transactions occurring at Bitcoin ATMs, it becomes challenging to effectively monitor and identify suspicious activity.
  2. Customer Identification: Ensuring the identity of customers conducting transactions at Bitcoin ATMs is crucial for KYC compliance. However, anonymity is a fundamental feature of cryptocurrencies, posing difficulties in verifying customer identities.
  3. Geographic Dispersion: CoinWorks’ Bitcoin ATMs are located in various geographic locations, each governed by different regulatory frameworks, adding complexity to compliance efforts.
  4. Regulatory Uncertainty: The evolving nature of cryptocurrency regulations globally adds a layer of uncertainty, requiring CoinWorks to stay abreast of regulatory developments and adapt its compliance measures accordingly.
  5. Know Your Customer (KYC) and Customer Due Diligence (CDD): Traditional financial institutions have well-established KYC/CDD procedures for verifying customer identities and assessing transaction risks. However, BTMs present unique hurdles due to their self-service nature. CoinWorks needs to implement effective KYC/CDD measures without significantly impacting customer experience.
  6. Anti-Money Laundering (AML) Program: CoinWorks must develop and implement a comprehensive AML program to identify and report suspicious activity. This program should include risk assessments, transaction monitoring, and suspicious activity reporting (SAR) procedures.
  7. Customer Identification Program (CIP): FinCEN regulations require MSBs to collect and verify certain customer information for specific transactions. CoinWorks needs to determine the appropriate CIP thresholds for BTM transactions and implement a system for collecting and verifying this information.
  8. Currency Transaction Reporting (CTR): MSBs are required to report certain cash transactions to FinCEN. CoinWorks needs to understand its CTR reporting obligations for BTM transactions and implement a system for accurately reporting these transactions.
  9. Bank Secrecy Act (BSA) Compliance: The BSA is a broad piece of legislation that governs AML and TF efforts in the US. CoinWorks must ensure its BTM operations comply with all relevant BSA provisions.

Hodder Law’s Approach

Hodder Law, a leading law firm specializing in FinTech regulations, was retained by CoinWorks to help navigate these compliance challenges. Our approach involved several key steps:

  • Regulatory Analysis: We conducted a comprehensive analysis of applicable FinCEN regulations and BSA provisions relevant to BTM operations. This included analyzing guidance issued by FinCEN and other regulatory bodies.
  • AML Program Development: We assisted CoinWorks in developing a robust AML program tailored to its BTM business model. The program included risk assessments, transaction monitoring mechanisms, and procedures for identifying and reporting suspicious activity.
  • KYC/CDD Procedures: We helped CoinWorks develop KYC/CDD procedures that strike a balance between effective identity verification and customer convenience. This could involve tiered KYC based on transaction amounts, with enhanced verification for higher-value transactions.
  • CIP Implementation: We assisted CoinWorks in determining appropriate CIP thresholds for BTM transactions and implementing a system for collecting and verifying customer information. This could involve a combination of document verification, selfies, and government-issued ID scans.
  • CTR Reporting Guidance: We provided guidance on CoinWorks’ CTR reporting obligations for BTM transactions. This included determining the types of transactions subject to CTR reporting and implementing a system for accurate reporting.
  • BSA Compliance Training: We trained CoinWorks personnel on BSA compliance requirements and their roles in implementing the AML program. This training ensured all staff understood their responsibilities and could effectively identify and report suspicious activity.

Benefits of Compliance

By proactively addressing compliance challenges, CoinWorks can enjoy several benefits:

  • Reduced Risk of Regulatory Enforcement: Effective compliance reduces the risk of regulatory scrutiny and potential enforcement actions from FinCEN.
  • Enhanced Reputation: A strong compliance program demonstrates CoinWorks’ commitment to responsible business practices and fosters trust with customers and partners.
  • Improved Risk Management: A robust AML program helps CoinWorks identify and mitigate potential money laundering and terrorist financing risks.
  • Efficient Operations: Streamlined KYC/CDD and reporting procedures can improve operational efficiency and reduce costs.

Approach to Compliance

To address these challenges and maintain compliance with AML and KYC regulations, CoinWorks has implemented a comprehensive compliance framework consisting of the following components:

  1. AML/KYC Policies and Procedures: CoinWorks has developed robust AML/KYC policies and procedures tailored to the unique characteristics of Bitcoin ATM operations. These policies outline the steps for customer identification, transaction monitoring, and reporting of suspicious activity.
  2. Customer Due Diligence (CDD): CoinWorks conducts thorough CDD on all customers using its Bitcoin ATMs, including identity verification and screening against sanction lists and watchlists. To streamline the process, CoinWorks has integrated automated identity verification solutions into its ATM interface.
  3. Transaction Monitoring System: CoinWorks utilizes advanced transaction monitoring systems capable of analyzing transaction patterns in real-time to detect potentially suspicious activity. These systems employ machine learning algorithms to adapt to emerging threats and minimize false positives.
  4. Employee Training and Awareness: CoinWorks invests in regular training programs to educate its employees about AML/KYC regulations and the importance of compliance. Employees are trained to recognize red flags indicating potential money laundering or other illicit activities.
  5. Regulatory Liaison: CoinWorks maintains open communication channels with regulatory authorities, seeking guidance on compliance matters and proactively addressing any concerns raised by regulators. This proactive approach helps CoinWorks stay ahead of regulatory changes and ensures alignment with industry best practices.

Results and Outcomes

By prioritizing regulatory compliance and implementing a robust compliance framework, CoinWorks has achieved several positive outcomes:

  1. Mitigation of Compliance Risks: CoinWorks’ proactive approach to compliance has helped mitigate the risk of regulatory penalties and reputational damage associated with non-compliance.
  2. Enhanced Customer Trust: Customers using CoinWorks’ Bitcoin ATMs have confidence that their transactions are conducted in a secure and compliant manner, enhancing trust and loyalty towards the brand.
  3. Regulatory Recognition: CoinWorks’ commitment to compliance has been recognized by regulatory authorities, resulting in positive relationships and a cooperative regulatory environment.
  4. Business Growth: Despite the regulatory challenges, CoinWorks has experienced steady growth in its Bitcoin ATM network, expanding its presence into new markets while maintaining compliance standards.


As the regulatory landscape surrounding cryptocurrencies continues to evolve, businesses operating Bitcoin ATMs face increasing pressure to ensure compliance with AML and KYC regulations. CoinWorks Inc. serves as a prime example of how proactive compliance measures can enable businesses to navigate regulatory challenges successfully while fostering trust among customers and regulators. By prioritizing compliance, CoinWorks has not only safeguarded its operations but also contributed to the legitimacy and acceptance of cryptocurrencies in the mainstream financial ecosystem.


  1. Financial Crimes Enforcement Network (FinCEN). (n.d.). Retrieved from
  2. Muhanna, R., & Watts, M. (2020). Anti-Money Laundering in the Age of Cryptocurrency. Journal of Financial Crime, 27(4), 1142-1163.
  3. Financial Action Task Force (FATF). (2019). Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers. Paris: FATF.

Disclaimer: This case study is for informational purposes only and does not constitute legal advice. Please consult with an attorney regarding your specific compliance needs.

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