Crypto exchanges, sanctions and compliance reviews: general information
A neutral explainer on how exchanges apply sanctions and restrictions, what "tainted coins" really means, and what users can do. Not legal advice.
Why this matters
Governments publish sanctions and other restrictions on persons, entities and in some cases crypto-asset platforms. Regulated businesses, including exchanges, must apply the rules that bind them and may also set stricter internal policies. This article is general information about how that usually works. It is not legal advice and it does not describe any individual's situation.
How exchanges typically apply restrictions
Most platforms combine identity verification (KYC), screening of customers and counterparties against official lists, and blockchain-analysis software that flags addresses linked to restricted parties. Each company decides its own thresholds, which is why the same address can be accepted at one venue and held at another.
What are "tainted coins"?
"Tainted" is not a legal status. No regulator maintains a list of dirty coins. Analysis tools trace where funds have travelled and give a risk score, and the score depends on the tracing method. The industry now prefers the word "exposure", and being a few transactions away from a flagged address is not the same as dealing with a restricted person.
Why a deposit or withdrawal can be held
A hold is usually a compliance review, not an accusation. Reviews are closed by evidence of the source of funds. In some jurisdictions a firm that files a suspicious-activity report is legally forbidden from telling the customer, so a short answer from support is not necessarily evasive.
Practical steps for users
- Screen the counterparty firstFor peer-to-peer transfers, check the address and the person against official lists before you accept funds.
- Know your local rulesRestrictions differ by country. You are responsible for complying with the ones that apply to you.
- Keep your own recordsExchange statements, trade confirmations and invoices are what resolves a review.
- Leave unsolicited small amounts aloneDo not sweep unexpected "dust" into your main balance.
- If funds are held, respond with documentsAsk what documentation is needed and provide it in one go.
What this means on mSamex
mSamex is operated by mSamex Cryptocurrency Exchange OÜ, a registered Estonian company. Use of the service is subject to the Terms of Service and the AML/KYC policy, which allow verification requests, reviews and holds. The service is not offered to US persons. Users must comply with the laws of their jurisdiction.
Questions people ask
Is 'tainted coin' a legal status?
No. No regulator keeps a list of 'dirty' coins. Blockchain-analysis software scores addresses, and the result depends on the method and thresholds each company configures.
Why would a deposit be held for review?
Exchanges screen deposits, withdrawals and accounts under their compliance obligations. A hold is normally a review, closed by documents that show the source of funds. Firms are sometimes legally restricted from explaining the exact reason.
Who is responsible for following sanctions and export rules?
Every user is responsible for complying with the laws that apply in their own jurisdiction, and with the platform's Terms of Service and AML/KYC policy.
What can I do to avoid problems?
Screen counterparties before accepting funds, keep records of where your funds come from, leave unsolicited small amounts untouched, and answer review requests with documents.