Exhibit DeskAML · crypto compliance · fraud

Typologies

Patterns worth a second look.

Each comes from a published Red flag and its primary source: the signal in the source's words, our read, and what we would check.

Red flag 002 · 9 Oct 2026

Structuring under thresholds

The alert shown is illustrative.

A red flag is a reason to look, not a verdict.

The Reel as text

The signal

“Structuring VA transactions (e.g. exchange or transfer) in small amounts, or in amounts under record-keeping or reporting thresholds, similar to structuring cash transactions.”

FATF, Virtual Assets Red Flag Indicators, September 2020

Our read

In Türkiye the limit itself makes lawful splits. Per MASAK, platforms cap stablecoin withdrawals at $3,000 a day and $50,000 a month (the limits may be doubled where the travel rule applies), so a larger lawful stablecoin sum leaves in parts.

  • Recurring payouts: payroll, freelancers, regular savings
  • A small test transfer before the large one

FATF: a red flag is “not necessarily a basis for a suspicion of ML or TF.”

What we would check

  • The sum of the transfers across days, linked accounts and assets
  • The wallet they go to
  • The stated purpose

We would set the alert on the total over the window.

The Red flag and its sources

Red flag 001 · 5 Oct 2026

DeFi in, fiat out

The alert shown is illustrative.

A red flag is a reason to look, not a verdict.

The Reel as text

The signal

“A customer receives stablecoin deposits from a DeFi service that lacks AML/CFT controls, converts the funds to fiat currency, and withdraws the proceeds.”

FinCEN Alert FIN-2026-Alert005, 3 September 2026

Our read

The same pattern fits an ordinary DeFi user cashing out gains, or someone who bridged their own funds to a chain the exchange supports.

  • A treasury rebalancing between on-chain venues and fiat

FinCEN: “no single red flag is determinative.”

What we would check

  • Trace the deposit one or two hops back through the protocol and screen the funder
  • Weigh the customer's history, as FinCEN asks
  • Look for related flags, as FinCEN asks

If suspicion of scam-center laundering stands, FinCEN asks SAR filers to include the key term FIN-2026-SCAMCENTERS.

The Red flag and its sources