Fraud Prevention, KYC, and AML Compliance for P2P and Crypto Asset Exchange Operations Κομμάτι εκπαίδευσης

P2P Exchange Operations and the Fraud Risk Landscape

• The escrow-based order lifecycle and asset release mechanisms.
• Identifying exposure points: off-platform fiat settlements versus on-platform crypto assets.
• Consequences of fraud, including losses, chargebacks, and bank claims.

Exercise 1: Mapping the Exposure: Teams will trace one buy order and one sell order from placement to release, identifying every point where off-platform payment disrupts the link between identity and funds.

Regulatory Framework and Supervisory Expectations

• FATF Recommendations, VASP obligations, and the travel rule.
• Crypto asset supervisory authority and exchange licensing requirements.
• Jurisdictional risks, grey-list monitoring, and sanctions exposure.

Fraud Typologies in P2P Trading

• Payment channel deviations and mismatched payer accounts.
• Triangulation, third-party payers, and the reuse of payment proof.
• Partial payments, altered amounts, and visually similar figures.

Case Study: Five Recurring Patterns: Participants will classify real, anonymised dispute records against five typologies and identify the control failure in each instance.

False Confirmations, Forged Receipts, and Account Takeover

• Orders marked as paid without an actual transfer occurring.
• Edited screenshots and falsified bank receipts.
• Cross-phishing in order chats and credential theft.
• Hijacked accounts being reused to defraud other users.

Workshop: Phishing in the Order Chat: Teams will compare a genuine support message with a fraudulent one, then draft the takedown and revalidation path for the reported account.

KYC for Individuals: Level 1 and Level 2

• Level 1 data capture and identity document review.
• Level 2 revalidation, video-selfie liveness checks, and list screening.
• Matching verified identity to the payment instrument.

Lab: Onboarding Under Pressure: Participants will conduct Level 1 and Level 2 reviews on sample files, recording the discrepancies that trigger revalidation.

KYC for Legal Entities and Beneficial Ownership

• Corporate documents, representation powers, and signatories.
• Beneficial ownership chains and control indicators.
• Risk factors for legal persons and periodic review requirements.

Identity Fraud and Document Forensics

• Forged, borrowed, and synthetic identities.
• Liveness bypasses, deepfake attempts, and injection attacks.
• Revalidation triggers following disputes or compromise claims.

Lab: Document Forensics: Participants will inspect tampered documents and screen captures for inconsistencies in font, layout, metadata, and account numbers.

AML Screening, Sanctions, and PEPs

• List matching, tolerance levels, and handling false positives.
• PEP identification, adverse media analysis, and source of wealth verification.
• Enhanced due diligence and escalation thresholds.

Customer Risk Assessment and the Risk-Based Approach

• Customer, product, channel, geographic, and behavioural factors.
• Risk rating, review triggers, and treatment decisions.
• Scaling due diligence efforts to match actual risk levels.

Transaction Monitoring and Blockchain Analytics

• Withdrawal approval criteria: account age, KYC status, and transaction history.
• Wallet attribution, high-risk counterparties, and fund tracing.
• Risks associated with chargeback-prone gateways and payment methods.

Case Study: The Large Withdrawal: Participants will review a withdrawal request with a mixed funding history, deciding whether to approve or escalate and justifying the decision against monitoring criteria.

Evidence Standards for Payment Proof

• Acceptable evidence: statements and uninterrupted recordings.
• Authenticity checks on documents, captures, and metadata.
• Recording what was verified and what was not.

Lab: Evidence or Artifact: Teams will sort a pack of submissions into acceptable evidence, insufficient evidence, and probable fabrication, stating what additional information should be requested.

Disputed Evidence and Interbank Delays

• Resolving cases where both parties submit valid evidence.
• Waiting periods for interbank processing and preventive holds.
• Documented decision criteria for time-expired orders.

Workshop: Both Sides Are Right: Teams will resolve a dispute where buyer and seller each hold apparently genuine proof, defending the final outcome.

Action and Sanctions Playbook

• Freezing collateral, restricting accounts, and suspensions.
• Partial payment deadlines and returns to the originating account.
• Refunds to incorrect banks: fees and resolution timeframes.
• Restricted balances and retention of new deposits.

Exercise: Writing the Sanction: Participants will draft the action, notice, and timeframe for three escalating cases and test them against playbook criteria.

Case Management, Documentation, and Escalation

• Case files, internal notes, and evidence retention.
• Escalation matrix and department head review.
• Suspicious activity reporting and record-keeping.

Capstone: End-to-End Fraud Case

• Order review, evidence assessment, and identity revalidation.
• Escalation, sanctions decision, and counterparty resolution.
• Justification memo and peer review.

Capstone: Full Case Run: Each team will handle a complete simulated case from the first suspicious message to the final decision, presenting a written justification for peer review.

Diagnostic and Advisory Session (Additional Component)

• Review of current practices and protocol gaps.
• Guidance on evidence standards and disputed cases.
• Guidance on actions and sanctions criteria.