Page 34 - Understandinging Forensic Technology Landscape
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Investigating blockchain ledgers is similar to       and certain other businesses to perform customer
           investigating other ledger activity. The goal is to trace   due diligence to ensure they know their customers.
           activity among accounts or across periods to identify   This type of compliance is monitored by the Treasury
           the source of the activity and/or whether transactions   Department’s Financial Crimes Enforcement Network
           are appropriate. Typically, information is gathered to   (FinCEN). The Department of the Treasury’s Office
           determine the timeline of transactions, the activity, and   of Foreign Asset Control (OFAC) offers a secondary
           the parties involved in the transactions. The benefit   mechanism for investigators in its publication of digital
           of tracing activity on a blockchain is that transactions   currency addresses that can assist compliance officers
           initiated on the ledger are validated to ensure the   in determining prohibited transactions. Indeed, in
           transaction actually took place. Once validated, the   November 2018, OFAC identified two digital currency
           transaction cannot be altered (for example, to give   addresses associated with malicious activity.
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           the appearance of activity during a different period
           or between different parties). Free tools such as    One well-reported example of an investigation involving
           Blockchain.com or Etherscan.io can aid in tracing    tracing activity on a blockchain ledger involves the
           cryptocurrency transactions. In addition, there are   investigation into Silk Road, an online black market
           several subscription tools such as ChainAnalysis,    that used bitcoin blockchain technology as the form
           Qlue and CipherTrace.                                of payment. When Silk Road was taken down by the
                                                                federal government, tracing activity between addresses
           Although the owner of a cryptocurrency address       led to the discovery that federal agents were involved
           may not be known, following activity between and     in inappropriate activity.  The discovery of forged
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           among addresses can still be accomplished either     documents was one piece of information that assisted
           through the use of blockchain explorers or proprietary   in the discovery that federal agents were benefiting
           technology. Forensic practitioners may be asked to   from illicit activity.  As one of the federal agent’s
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           investigate blockchain activity related to Know Your   cryptocurrency increased, it triggered certain KYC
           Customer (KYC) and anti-money laundering compliance.   reporting requirements by the digital exchange where
           Financial regulations require financial institutions   the federal agent had established his account.
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            36   Treasury Designates Iran-Based Financial Facilitators of Malicious Cyber Activity and for the First Time Identifies Associated Digital Currency Addresses, November 2018.
             home.treasury.gov/news/press-releases/sm556, accessed November, 27, 2019
            37   Former DEA Agent Sentenced for Extortion, Money Laundering and Obstruction Related to Silk Road Investigation, October 19, 2015. justice.gov/opa/pr/former-dea-agent-sentenced-
             extortion-money-laundering-and-obstruction-related-silk-road, accessed November 27, 2019; Former Secret Service Agent Sentenced in Scheme Related to Silk Road Investigation,
             November 7, 2017. justice.gov/opa/pr/former-secret-service-agent-sentenced-scheme-related-silk-road-investigation. Accessed, November 27, 2019
            38   Stealing bitcoins with badges: How Silk Road’s dirty cops got caught; Cyrus Farivar and Joe Mullin, August 17, 2016. arstechnica.com/tech-policy/2016/08/stealing-bitcoins-with-badges-
             how-silk-roads-dirty-cops-got-caught/, accessed November 27, 2019
            39   United States of America V. Carl Mark Force IV, et al, United States District Court for the Northern District of California, Gambaryan Affidavit, p. 36: 18-21. justice.gov/sites/default/files/opa/
             press-releases/attachments/2015/03/30/criminal_complaint_forcev2.pdf, accessed March 18, 2020




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