Richard Malish is General Counsel at NICE Actimize where he counsels on global anti-money laundering, fraud, trading compliance and banking regulatory matters.
The New York Attorney General ("NY AG") recently issued a report on its fact-finding enquiries to multiple virtual currency trading platforms believed to be operating in New York. One of its many interesting findings was how virtual private networks ("VPNs") may permit market manipulation.
VPNs are a critical tool for privacy-minded cryptocurrency traders, as well as the only method for some traders to access these markets in countries such as China. Based on the NY AG's report, should crypto exchanges assume that VPN access is no longer permissible?