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[00:01:56] How did Amanda get started in prosecuting money laundering in crypto?

[00:02:39] Why did Amanda start the Association for Women in Cryptocurrency?

[00:03:58] What are the catalysts reshaping the future of digital finance?

[00:04:48] How does social engineering pose a threat to crypto security?

[00:06:37] Why don't traditional financial regulations work well for cryptocurrency?

[00:10:47] How can brands stay ahead of evolving security threats?

[00:13:24] What role does AI play in enhancing crypto security?

[00:15:28] How can exchanges educate customers about crypto safety?

[00:17:31] Why is it important to understand different regulatory environments?

[00:18:50] What's the value of conducting a security risk assessment?

[00:21:01] How can robust data security practices drive revenue?

[00:24:41] What is the future of privacy in cryptocurrency?

[00:28:38] What role does the customer experience play in building trust?

[00:32:31] How can brands build trust in an era of declining institutional trust?

[00:00:00] Robert Zirk: Cryptocurrency and digital finance have revolutionized the way people send and receive payments and invest their money. These technologies provide autonomy and make financial services more accessible.

[00:00:15] But underlying this convenience is complexity. As financial technology evolves, so do the risks for consumers and brands alike. Cybercrime and sophisticated scams have made customer trust both more vital and more difficult to maintain for financial services and crypto brands, with a Pew Research Center study revealing that 63% of Americans are skeptical about the safety and dependability of cryptocurrency transactions.

[00:00:49] On this episode, I'm joined by Amanda Wick, founder and CEO of the Association for Women in Cryptocurrency, principal at Incite Consulting and author of The Catalysts: The Accelerating Forces Forging the New World Financial Order. Drawing from her background as a crypto advisor and former U.S. federal prosecutor specializing in financial crime, Amanda will share her perspectives on the biggest trust and safety challenges crypto and fintech brands face and how these brands can turn confidence into a competitive advantage.

[00:01:22] So today on Questions for now, we ask: How can crypto and fintech brands prevent fraud and maintain customer trust?

[00:01:39] Welcome to Questions for now, a podcast from TELUS Digital, where we ask today's big questions in digital customer experience. I'm Robert Zirk.

[00:01:53] Robert Zirk: Amanda's journey in crypto began in 2012 while she was a federal prosecutor at the U.S. Department of Justice, or DOJ.

[00:02:00] Amanda Wick: I was predominantly a money laundering and asset recovery prosecutor and one of my agents came in and said, "Do you know what a Bitcoin is?"

[00:02:08] And I said, "I don't think that's a real thing." And he said, "No, it is. And I'm pretty sure we got a guy laundering a lot of it, so we need to learn what it is."

[00:02:15] And back then there wasn't a formal training program, so we went to Google and YouTube and learned what it was. And then, over the course of the next seven or eight years, I focused predominantly on crypto money laundering and tracing dirty crypto.

[00:02:28] Robert Zirk: Following her time at the DOJ, Amanda became chief of legal affairs at Chainalysis, a blockchain analysis firm, and founded the Association for Women in Cryptocurrency.

[00:02:39] Amanda Wick: When I left the government and went to Chainalysis, I was struck by how different it was for women in the tech industry, especially in crypto. You would've looked around the industry and thought there were no women, but there were actually hundreds, if not thousands, of women doing really incredible things. And so I was like, "There's a community here that needs to find each other."

[00:02:57] We're a professional advocacy association because we're both a professional association and advocacy. And so there's an educational aspect and professional development. And then we also build a global network of support so if you're looking for a job, if you have questions, you're looking for a mentor, sponsors, we have a program for that. And we do events all around the world.

[00:03:19] The advocacy piece is probably what separates us, where it's a very active advocacy. So we have an initiative that we started last year called "Unmanel Your Panel", and this is where we just work with folks, especially conferences, to be more intentionally inclusive, to make sure that they know there's lots of women. We have a global inclusive speaker directory of over, I think, two or three hundred women and allies who are interested in speaking on a plethora of topics.

[00:03:45] Robert Zirk: Amanda recently authored her first book, The Catalysts: The Accelerating Forces Forging the New World Financial Order, which examines the factors that are reshaping the future of digital finance and the risks they present collectively.

[00:03:58] Amanda Wick: If you just look at the invention of cryptocurrency and disintermediate finance,

[00:04:02] Robert Zirk: ...which is the ability for people to invest and transact directly with one another without an intermediary, like a bank...

[00:04:09] Amanda Wick: ...if you just look at social engineering, if you just look at the rise of tech nation states, if you look in these massive things as silos and you don't take a 360 view, you miss a lot.

[00:04:21] So the book is really a breadth not depth book about all the forces that are basically clashing together to really impact what's happening in the world, especially financially, and how policy makers and regulators need to look at that entire aperture in order to be ready for what's coming.

[00:04:38] Robert Zirk: In her book, Amanda warns brands to be more cognizant of the threat posed by social engineering, particularly when combined with big data and AI.

[00:04:48] Amanda Wick: It's really terrifying because a lot of communities and societies in the world stopped teaching critical thinking. So you have a drop in a consumer's ability to be cognizant of it or to critically think or sift through all the misinformation and disinformation that's being pumped to them in algorithmically created social bubbles that they live in.

[00:05:11] And this isn't a political issue. This is on both sides of the political spectrum. And then you have this massive rise in transnational organized crime that is looking at social engineering, is looking at AI and crypto, and is using all of those tools to defraud people or to scam people. And that's wildly problematic.

[00:05:32] And whether it's Australia, the U.S., Canada, the U.K., you're talking about, like, generational wealth being lost to fraud scams at a level that's just proliferating and growing. And governments and law enforcement aren't even close to catching up or being ready to deal with that. And so it's not so much crypto crime, it's crime that's exploding that crypto happens to be used for and no kind of coordinated transnational government response — like, crime is organized and the government's response is not, and that's a massive problem.

[00:06:06] Robert Zirk: In financial services, it's important for brands to comply with various regulations to prevent criminal activity. These include KYC, which is Know Your Customer, and AML, or Anti-Money Laundering. Remember, this was Amanda's area of expertise as a federal prosecutor. Amanda noted that regulations created for traditional finance, or TradFi, don't always apply well to cryptocurrency as they were created and enacted long before crypto existed.

[00:06:37] Amanda Wick: We actually probably need new regs that are principles-based in the sense of, if what you wanna do is fight money laundering and terrorist financing, and if what you wanna do is no counterparty risk...

[00:06:49] Robert Zirk: ... which is the danger of unknowingly doing business with someone involved in illicit activities...

[00:06:54] Amanda Wick: ...then what does that look like in crypto? Because what's really hard in crypto compliance is transaction monitoring is actually really great.

[00:07:02] Robert Zirk: For example, if you wanted to deposit $10,000 in a traditional bank, you'll have to go through the bank's KYC processes. And while you may be subject to some questioning about the source of your funds, your bank won't be able to analyze the serial number on every individual bill and look up detailed ledgers showing that, several transactions ago, the money was used to finance a crime.

[00:07:25] But consider the functionality of a blockchain. The ledger is open and every transaction is mapped to an address, meaning it's possible to trace the path of the funds.

[00:07:36] Amanda Wick: In crypto, if I do a transaction, if I have a wallet and I send my address to the exchange, they can look back and say, "Uh, four hops ago, this woman's funds came from a darknet market, so there's a really good chance that she's doing something that she shouldn't." That level of transactional visibility actually makes AML/CFT ...

[00:07:58] Robert Zirk: ... which is Combating the Financing of Terrorism...

[00:08:00] Amanda Wick: ... in crypto wildly doable. And, like, the visibility level is huge.

[00:08:05] So when crypto compliance officers are doing transaction monitoring and these tools are just hitting them with so many alerts, part of the problem in crypto compliance is it was already hard enough to get resources in TradFi when it was a opaque house.

[00:08:22] Robert Zirk: To explain compliance challenges. Amanda shared this analogy: in traditional banking, inspecting accounts is like looking into a brick house from the street.

[00:08:31] Amanda Wick: And you're like, "Well, it's really hard to tell what's happening in there because there's no visibility. So I gotta go knock on the door and say, ' How clean is this house?'" And of course the owner's gonna be like, "It's super clean. It's super clean. Stand outside, peer through the windows. See if you can see through the curtains and just take a look around." And so you go over and you're like, "Okay, well, in this window is a living room, it looks pretty clean. I can't really climb to the second floor. Maybe I can get a ladder." But they've shoved everything in closets or everything on the other side of the house is filthy, right?

[00:09:01] Robert Zirk: The difference with crypto is that the houses are made of glass, not brick.

[00:09:06] Amanda Wick: We've been able to see the illicit finance rates of exchanges. We know exactly who has really, really good compliance programs and who didn't have some. You could literally see they're gobbling up billions of dollars in transactions and their compliance department is non-existent. Look at their illicit finance rates. They're through the roof, right? That's incredible when you think about monitoring money laundering and terrorist financing.

[00:09:29] But the problem with a glass house is that you can see exactly what's inside, which means that now that same reporting requirement is actually a pretty heavy burden because you don't get to leave your room messy and you don't get to use the curtains and you don't get to use the bricks to hide what's going on because everybody can see exactly what's going in and out.

[00:09:49] And so that's the problem with crypto compliance is you're kind of like a victim of your own success. You have a lot of visibility in transaction monitoring, and so there's this risk that a lot of exchanges may not use their tools, may not be looking, may not be triaging alerts fast enough because there's so much visibility that, to do it the same way that TradFi does, they're gonna probably need a lot more resources and time.

[00:10:16] Robert Zirk: In 2023, the FBI estimated more than $5.6 billion were lost related to cryptocurrency fraud — a 45% increase over the previous year.

[00:10:28] As crypto fraud escalates beyond available resources, a trust and safety partner like TELUS Digital can help brands stay on top of the latest tactics and trends in financial crime and compliance with the scale, experience, and technology capabilities to protect brands and their customers.

[00:10:47] Amanda pointed out that security risks in crypto can range from social engineering to physical safety, with some individual hacks having eclipsed the billion dollar mark. The misuse of AI by threat actors adds even more complexities to the security challenges fintech and crypto brands face.

[00:11:06] Amanda Wick: A lot of people talk about deepfakes. I've had some law enforcement friends who have posted videos where I've been pretty horrified at how close it is to the real thing. And obviously that's really scary because whether it's executives or corporate employees, hackers trying to get in, either get access, get funds through that is getting harder and harder to detect.

[00:11:26] The other thing is phishing and spear phishing generally. I think in the past a lot of prospective fraud victims, if one of the messages came in on your text or in an email — especially emails — where the language didn't make sense or it seemed like somebody was writing to you in a foreign language, now with AI and all kinds of other tools, they can sound perfectly reasonable. They can spoof websites coming at you so much easier. So I think it's just all of the things that they can do to simulate being real to be able to actually manipulate what you're seeing on the user interface versus the transactional activity that was actually happening. That's wildly problematic.

[00:12:03] Robert Zirk: So how are crypto and Web3 companies doing overall in terms of their security?

[00:12:08] Amanda Wick: Frankly, I think all of the crypto companies could be doing much, much better on the security aspect. And part of that is not entirely crypto's fault. Some of it's just when you're digitally native, like when everything is so reliant on tech and the criminals are so much better at tech, I think it just creates a lot of vectors for attack.

[00:12:32] Robert Zirk: When it comes to security, brands are in a constant sprint against threat actors looking to gain and exploit an advantage and it's crucial to recognize that, as important as it is to maintain a lead, the race has no finish line.

[00:12:46] Amanda Wick: More brands really need to be proactive about worst case scenario planning, because I think a lot of them sometimes think about, like, the baseline requirements and they don't realize that all day, every day hackers are trying to figure out ways to get in through those doors. So if there's something Googleable that they're kind of like, "Okay, well I've checked this box," the hacker knows what the box is. So you need to be better than that and you need to be thinking about having higher security standards. you need to be thinking about if criminals are using AI tools to get into our security or to defraud our customers, maybe we should be using AI-driven tools to combat that back.

[00:13:24] Because if you've got AI on the attack and you've got humans as the defense, I know people love to think that we humans are great, but realistically, you wanna fight fire with fire.

[00:13:34] There are definitely companies that are integrating AI both into KYC, into AML, into identity verification and even into blockchain analytics.  AI can do massive large scale data analysis and do incredible things that, frankly, humans can't.

[00:13:51] And so having AI tools on the backend as a company is something that's really critical and I think is becoming less a want list item and a must-have item going forward in the future.

[00:14:04] Robert Zirk: According to security.org, 36% of American crypto holders are concerned about cybersecurity threats and losing access to their digital wallets. So strong security measures aren't just for the benefit of the business. They're a fundamental expectation of the customers you serve.

[00:14:21] When customers entrust their money to a financial platform, they're doing so with the expectation that their assets will be protected. If a brand becomes known as an easy target with which to facilitate cybercrimes, the damage to the brand's reputation and integrity can be irreparable.

[00:14:40] Amanda highlighted the importance of fostering a culture of safety that not only fortifies your operations, but is also apparent to customers.

[00:14:49] Amanda Wick: When I think about crypto exchanges, Binance comes to mind and a few others, they have entire academies where they are doing customer education and they have videos.

[00:15:01] And I think Coinbase, just to use an example, has a feature where before you make a transfer, it'll say, do you understand that? Going from this protocol to this protocol. Like just making sure that you know how this works, right? Because it's far techier than if you're just in your bank, right? Doing transfers between accounts or wiring money from one person to the other. There is a autonomy to it that requires a little bit of tech savvy and understanding how the protocols work.

[00:15:28] And some of the exchanges unfortunately are, I don't wanna name names, but, like, some of them are becoming pretty well known if you're on like Reddit or some of the thread forums of: who has MFA?

[00:15:37] Robert Zirk: ...which is multifactor authentication...

[00:15:40] Amanda Wick: Who's doing the things to protect people? Who has VPN checks or IP address checks to see, like, hey, are you looking at activity that would suggest that this person has access from the same location every time and all of a sudden it's a VPN or a different IP address, which is an indicator of fraud.

[00:15:55] Robert Zirk: Being proactive means that laws and regulations are only where the checklist begins. And often, those regulations aren't comprehensive enough to fully cover the scope of consumer protection that's necessary, or to keep up with the pace of cybercrimes.

[00:16:10] Amanda Wick: There's an exchange in Australia, BTC Markets, and they go way above what they have to legally do for compliance. And I know the CEO herself has spent hours with a customer begging them not to move their funds because it was a scam, explaining, explaining, "This person who's been communicating with you for six months is not your fiancé. Like, they are not real, you are being sc-", and you can imagine how difficult that is in this scam that has an aspect of romance in it. It's really hard, right? And the CEO herself is on the phone for hours doing everything she can to protect a customer who's literally been duped from months into believing this.

[00:16:45] And so when you think about that level of concern for the customer, that's the kind of thing that I think brands need to be thinking about is: are you waiting for either the law or a regulator or some kind of government agency to mandate that you do certain things? Or are you looking at what best practices are and figuring out "How do we put these into place to prevent something from happening to our customers?" as opposed to doing the cost-benefit analysis of "What's the bare minimum that we have to do to prevent getting some kind of fine or in trouble with the government?", which is really never a good policy.

[00:17:23] Robert Zirk: And it isn't just one government at that. Brands need to be aware of the different regulations in every jurisdiction in which they operate.

[00:17:31] Amanda Wick: I think people don't realize, even within the United States, it's particularly difficult because you have federal regulations and then you might have 50 different state regulations to contend with. And if you have a customer sitting in Wyoming and a customer sitting in Massachusetts, hopefully you understand the differences between those state regulations on top of the US federal requirements.

[00:17:53] If you're moving money or transferring funds, odds are pretty good that some regulations apply to you, right? It's really important for companies to understand "what's the risk?" Interestingly, when I was at a blockchain analytics company, they're not financial services. They don't touch funds at all. They're just a SaaS company, a software as a service company. But if you are an American company, you still have to have a sanctions program.

[00:18:20] You have to make sure that you are not selling your product into Iran or North Korea, or people who are in certain countries who are pretending, right? Maybe using a VPN to get around that. Like, you need to have certain security protocols so that you're not violating sanctions.

[00:18:36] Robert Zirk: Whether you're building your security processes from the ground up, trying to ensure compliance with regulatory standards, or looking to bolster your existing safeguards, Amanda advises starting with a security risk assessment or risk profile.

[00:18:50] Amanda Wick: Everybody loves to think that their security is great or that they have the best procedures. It's just always a good thing to get an objective third party to come in and say, "Hey, this is what you're looking at."

[00:19:01] There are companies out there that build really good reputations for, "I'm not just gonna say this because I wanna sell you something. I'm gonna tell you the truth. Oh, your security's pretty good actually. Like, you could do this, this and this to make it better, but overall, like, okay." I think that's a reputation that you build in the industry. Like, do they sell you stuff that you don't need or are they straight shooters?

[00:19:21] I think what's really, really hard is the ability to step back and objectively view something or let somebody come in and say, "Will you review this? Because I can't be objective and I can't be unbiased." If you're a C-suite executive, it does not take away from your brilliance to bring in an outside vendor to do a security assessment, to test your protocols, to test your consumer protection standards.

[00:19:43] If you don't have certification, if there are standards that have been set, whether it's SOC 2, CCSS, whatever it is, right? If you don't know what those are and you're not meeting them, it can cause all sorts of problems. And people are figuring this out because I know even some insurance brokers and insurance companies who are looking at this and are now building this in to say, "Are you doing this? Because we're gonna charge you higher premiums if you're not doing the things that are necessary."

[00:20:11] So there's all kinds of collateral benefits to having good security and the things that you need to either protect consumers, protect your employees, protect your company, because other people are becoming aware of what best practices are and if you are not doing it, your insurance might be higher, your risk might be higher, right? Like tons of things. Reputational risks that you open yourself up to. There's just a lot of things that are risk.

[00:20:36] And so it's just a question of who you want to be, what product you want to deliver for your customers and how safe do you want to make your company. As safe as you know how to make it? Well, if you're not a security expert, guess how safe that likely is. So calling security experts? Probably something that you should do just to be safe.

[00:20:55] Robert Zirk: To that point, Amanda mentioned that brands would also benefit from having guidance at the board level to ensure you're thinking strategically about your trust and safety program.

[00:21:05] Amanda Wick: Who's on your board? Who's advising you to be thinking about this in a really helpful way? There's lots of people who do this work.

[00:21:12] So if you're sitting out there and there's not somebody on your board who has asked you about your data management, your data protection policies, what's your security risk protocols like, have you done a risk assessment for the company?

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