the three co-founders of BitMEX in late 2020 with willfully breaching American banking laws by allowing customers to sign up to the cryptocurrency betting group using fake passports and other incorrect information so that they could avoid anti-money laundering laws.
By the time Dwyer moved to Bermuda, BitMEX was a big deal in the cryptocurrency scene. Its point of difference to other exchanges was to offer its members ways to bet on cryptocurrency prices without owning any cryptocurrencies themselves. This involved selling highly risky derivatives, which are illegal to sell to Americans.
“Dwyer aided and abetted BitMEX’s failure to institute AML or KYC programs despite closely following US regulatory developments that made clear the legal obligation to do so if BitMEX operated in the United States, which it did.