Bitcoin Forum

This post is about exchanges that allow their customers to deposit, trade and withdraw bitcoins and other cryptocoins, without any need for verification (that is, to send our personal documents) and also allow trade of fiat, but not deposits or withdrawals of fiat.

Therefore, these exchanges don't allow any money laundering (since it's necessary to transfer the money to the banking system in order to "clean" it), but they respect our privacy.

www.btc-e.com
www.bitfinex.com
www.virwox.com
www.bitvc.com (the new Huobi exchange)
www.okcoin.com  (only mobile verification if you only deposit/withdraw crypto)

Lower volume:
www.justcoin.com (only mobile verification)
www.therocktrading.com
www.bitkonan.com
www.crypto-trade.com
www.mcxnow.com (they have their mcxBux, pegged to the USDs, but with very low volume)
www.vircurex.com (but after the hack, is a dying exchange)
https://goc.io/
https://c-cex.com
https://bx.in.th (Thai Baht, no USDs)
https://hitbtc.com

Some exchanges are trading now alt coins pegged to the USD, like Poloniex and the CoinoUSD (XUSD). Other second generation systems, like BitSharesX (with its BitUSD), NXT and, I guess, Counterparty (didn't confirm this) are trading other tokens/assets pegged to fiat coins. The problem is that if you want to use them as safe haven, you'll have to trust the exchange/system and the pegged coin.


anxbtc.com, unfortunately, allows non-verified to deposit, withdraw and trade cryptocoins, but not to trade fiat, even if we don't want to withdraw fiat. It's absurd.

cryptsy.com is in the same situation.

Kraken also has so low limits for customers that only gave their name and phone, even if they only deposit and withdraw cryptocoins (no documents: their Tier 1), that is irrelevant.


Any contributions, for example, about chinese exchanges, will be welcome. Exchanges with very low volume are also of little relevance.

BX.in.th (https://bx.in.th)

You only need to verify your ID if you want to deposit or withdraw fiat.

why not try LakeBTC (https://www.lakebtc.com/users/sign_up?ref=shw5yx&locale=en), you need to AML/KYC when you withdraw.

Of all these, I can very highly recommend bitfinex, as the exchange with some of the most fair regulations & features. About the only complaints I have are:

-> The rules on swaps are a bit confusing. For example, you pay for a swap if you reserve it and cancel it within the hour. If you just open a leveraged trade, you don't. You can't re-lend borrowed funds (which is a bit of a buzzkill and kind of explains the weird action over there). There are many similar oddities.

-> They reversed trades in one extreme situation.

The support team is nice and helpful, so of all these exchanges, its the one I trust most.

Any other exchange that allows to trade fiat and cryptocoins without verification, if we don't deposit or withdraw fiat?

The issue you'll find is in order to not have all your money seized (at some point) if you want to trade FIAT your gonna have to get verified somewhere.

None of the exchanges I quoted above require any kind of verification to just trade fiat. Customers deposit in crypto and withdraw again in crypto, even if in between the crypto were exchanged to fiat and back to crypto.

The goal is to have a safe haven for bitcoin volatility and to earn some profit trading.

Since no one can do any money laundering by just depositing and withdrawing in crypto (the fiat they hold in between are just bits on your exchange, the money never leaves your banking accounts) there is no point in asking for verification to just trade in fiat.

Sorry for the criticism, but Cryptsy is just alienating customers and trade volume by asking for verification to simple traders. You should only ask for verification if the customer wants to withdraw or deposit fiat. And you are losing for competition from all the quoted exchanges above.

Privacy is one of the core values of Bitcoin and sending personals documents is a risky move. I wonder where are all the personal documents that were stolen from Gox.

I hope you change this policy. Many traders (including me) would be there trading fiat at Cryptsy.

See the thing is you cannot change it and anyone engaging in that activity will eventually be shut down its simply not no have Anti Money Laundering (AML) and KYC (Know Your Customer) wish I had a better answer.

+1 on that.
Going in and out with BTC, LTC and now DRK is no problem, with them only knowing a username and emailadress.

The day this isn't possible any more on any exchange, is the day I leave for localbitcoins.
After the whole mess of MtGox leaked customer data I won't ever give out an ID scan on the internet.

Ente

Usually, I don't repeat arguments. I just give up and ignore the issue. But in this case, I'm going to repeat myself thinking more about other exchanges, like anxbtc.com:

1) If an exchange allows deposits and withdrawals of fiat, it's better for its future to have an AML and KYC policy. No doubt about that.

2) But if there are customers that are only allowed to deposit and withdraw cryptos,  there is no need to demand respect for the AML and KYC. Because those customers got nothing from sending the crypto and withdrawing the crypto again.
They couldn't clean their cryptos by inserting them (converted in fiat) in the banking system. If they are terrorists, they got nothing. Crypto they had, crypto they still have. Under US law, they were trading commodities/goods, not financial assets (bitcoin isn't money, they decided...).

3) Now, does it change anything if they traded their crypto for fiat, if they can't withdraw the fiat? Is there any point on demanding that they verify their account? The fiat is stuck, they can only convert it again to crypto and leave as they entered, with crypto.

4) If an exchange wants to take the policy to the last consequences, it has to adopt Bitstamp policy: every customer has to be subject to KYC policy (as I wrote, this isn't any AML policy, because it's impossible to clean money without withdrawing fiat). But everyone already knows how that will end, like Bitstamp is ending. I traded there almost one year. Never again sent there a satoshi.

The Chinese are starting on the BTC/USD too. The new Bitvc from Huobi, since it doesn't allow deposits or withdrawals of fiat, doesn't even ask for any personal information: privacy, 0 fees, high volume, margin/lending system... compete with it or die.

With most exchanges transferring bitcoin to other altcoins doesn't require any ID. but as soon as you try to withdraw fiat then most exchanges require ID for legal purposes.

I think bitstamp might revert back and instead adopt a bitvc-like policy of demanding to either just send coins back to wherethey came (with the profit or loss of course), or to send them someplace they "know" (you tell them).

Not like this, you say these doesn't require authentication only when you trading, but if you want to withdrawals, you must be verified.


And you can do deposits and trading on the following big exchanges don't need to complete the verification.

BTC-e (https://btc-e.com/)

Bitfinex (https://www.bitfinex.com/)

LakeBTC (https://www.lakebtc.com/)

and more exchange you can see: https://bitcointalk.org/index.php?topic=695082.0

I was talking about fiat money (governmental money, like USDs, euro, etc). Even in BTC-e and Bitfinex you have to verify your account to be able to withdraw fiat.

I don't have an account at lakebtc.com, but their FAQ (https://www.lakebtc.com/s/help?locale=en#verification) says that customers must verify. Perhaps, that is there only for legal reasons, but until confirmation I have to assume they want IDs from everyone.

No exchange implements KYC and AML policies because they decided it would be smart to create a lot of expensive unpaid work for themselves or because they want to alienate customers. Exchanges implement KYC and AML policies because in most jurisdictions if they don't they are unlawful MSB.

Your claim that not withdrawing fiat means no KYC/AML requirements is false in the US (and probably in false in many other jurisdictions).

http://www.fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html

Likewise the claim that AML only applies to "money" is also false (at least in the US).  The statutes are very broad and vaguely defined (some would argue too broad).   "Money" transmission is defined as "the acceptance of currency, funds, or other value that substitutes for currency from one person and the transmission of currency, funds, or other value that substitutes for currency to another location or person by any means".

Calling it value transmission and value laundering would probably be more consistent with that actual definitions.

FinCEN's guidance would only apply to US based exchanges (and exchanges doing business with US residents) however other countries are coming out with similar policies.  The US isn't unique it simply moved first.  Prematurely and in a haphazard manner but not unique. Take a look at prepaid credit cards for example, at one time almost no country regulated them and now almost all do.  It is an inevitability.   Non-compliant exchanges will eventually be shut down and in the process customer funds seized and frozen.   Technically customers could file a claim but just ask the players of full tilt poker how painfully slow that process is.

Yes, it doesn't require verified that you open a lakebtc account and the deposits, nor do the trading, but you can't withdrawals without verified.

Bitfeinx is so.

BTC-e doesn't need to verify only for virtual currency.
But also you need to verify as long as the deposit/withdrawal by wire transfer.
And if you need to cash withdrawals, you must do it.
Or you use other third-party payment (Egopay, OkPay, etc..) which they will ask you to complete the verification too.

I'm pretty sure when they say exchange virtual currency for other virtual currency, they mean something like Liberty Reserve to BTC. Trading BTC to USD on an exchange where you can't withdraw the USD actually just effectively exchanges BTC for BTC. If they really try to enforce that, first off they can't really, secondly exchanges would just use a CFD/Swap/Future to substitute for actual USD.

1) The quoted sentences are not from a legal statute, not even from an administrative regulation, it's just an re-elaboration on an administrative regulation, so a subjective interpretation from the Fincen about the Bank Secrecy Act. It's a reinterpretation of an administrative interpretation.
Even the regulations themselves are not binding on any court. The courts alone have the final power to determine the content of the Act. I have serious doubt any court would consider that an exchange trading only on crypto would be subject to the Act as a money transmitter.

2) Even the new regulations adopted on 2011 (http://www.gpo.gov/fdsys/pkg/FR-2011-07-21/pdf/2011-18309.pdf) about the concept of money transmitter by the Fincen (again, just their personal interpretation of the Bank Secrecy Act)  say nothing about virtual currencies. The vague notion is ‘‘other value that substitutes for currency’’.
In this 2013 reinterpretation, even Fincen argues that this notion only applies to convertible virtual currency.

Think about the Lindens in Second Life. It's the Game that emits them and buy them again, so it's a convertible virtual currency.

But there are other games that refuse to buy back their currencies and state that they have no value. So, these virtual currencies are not convertible and are not subject even to this subjective interpretation of the Fincen. But imagine that this virtual currency is exchanged for money by users and traders? Does this changes its nature? For the Game, no, it doesn't accept to convert it in fiat.

Now, think about an exchange that only accepts the trade of cryptos, even if that crypto is converted in fiat by other exchanges and traders. Is this exchange that only allows its customers to trade in crypto a money transmitter? I don't think so. Like the mentioned Game, they don't accept the cryptos that are traded as convertible. They don't pay or accept any customer to pay fiat for those cryptos. If third parties do that, it's their nature that is changed. Exchanges that allow their customers to exchange only cryptos are not allowing any trading of convertible virtual currencies.

A centralized virtual currency that is traded for fiat by its creator is always a convertible virtual currency. A De-Centralized virtual currency has no creator, so has no intrinsic nature as convertible or not. Some might convert it, some might not. Indeed, there are many cryptos that no exchange trades for fiat. Clearly, they are non convertible virtual currencies.

But if an exchange doesn't allow its conversion, it's not convertible in front of that exchange, therefore the exchange isn't a money transmitter.

If someone trading something that is accepted by some traders as convertible in fiat would be a money transmitter, well, half the Ebay traders would be money transmitters. Think about stamp sellers or all things that people collect and pay well for. And all goods have value in fiat and can be traded to fiat. Applying blindly those regulations would force most traders of goods to register with the Feds and the 48 states as money transmitters. That is absurd.

However, can't we argue that bitcoin is different? It's accepted as mean of payment by thousands of merchants and traded for fiat in many exchanges, can't we consider it as convertible virtual currency?

Well, the US government qualified it as a commodity for tax reasons. And the regulations apply only for the trade of convertible virtual currencies to another convertible virtual currency. No other crypto has the same status of bitcoin. Therefore, exchanges trading bitcoin for cryptos are not money transmitters.

Now, what about an exchange that allows its customers to trade crypto for fiat? We could argue its their customers that are accepting the crypto for fiat, not the exchange. But let's accept that the exchange is indeed giving convertible nature to the crypto and, so, it's a money transmitter.

Does that mean it's forced to adopt KYC policies against all of their customers, even the ones that can't withdraw fiat, but only crypto? I don't think so, because the goal of the KYC policy is indeed to combat money laundering and you can't clean money without inserting it in the banking system.

In any case, at most, that would be a violation of KYC duties and this isn't a crime, just a minor infraction. It wouldn't be possible any money laundering. At most, it would be imposed the payment of a fine. If the exchange had a KYC policy to customers with the ability to withdraw fiat, probably it would only determine a warning.

Anyway, those are just arguments, and the main one is: point me a court decision that supports a decision to close an exchange that doesn't allow withdraws in fiat or you won't have any Law on the issue, just opinions and vague legal precepts. Currently, there are no Law forcing exchanges to impose KYC if they don't allow withdraws in fiat, just opinions.

And those are american regulations. Any exchange just have to avoid using american addresses (like .com), avoid american servers and having property in american soil that can be seized, to be basically safe from any future change in American Law. And no case will be open to foreign exchanges because of a minor infraction, even if they have american customers.

But my main point was about being absurd to allow unverified customers to trade crypto, but not fiat, if they only can deposit and withdraw crypto.

While your right FinCEN's guidance isn't law, it is showing you their playbook when they seek civil and criminal penalties for those in non-compliance.  Ultimately (like any legal question) it will be decided by a judge.  However if you lose in court you don't get a do over, you don't get a "ok makes sense, I promise to not do that anymore" most likely you are now financially ruined and there is a good chance you just lost your freedom as well.

So if you disagree with FinCEN's guidance then feel free to open an exchange which goes against their guidance.  If your right, then it should be amazingly profitable for you.  If you are wrong, there is a good chance that eventually you will be bankrupt and looking at the possibility of decades in prison.  Most people don't like to play the "I think the govt is wrong" game with those kind of stakes on the line.  Your other option is to seek an administrative ruling but barring the slim to none chance that FinCEN agrees with you, that will just put you back in the same situation.

Ultimately if you think the statutes don't apply and FinCEN thinks they do then eventually you are going to end up in front of a judge.  When that happens what you think, I think, or even FinCEN thinks is irrelevant.  At that point the only thing that matters is what the judge thinks. Unless have strongly researched legal opinions that a judge would find flaw in FinCENs guidance then anyone taking your legal advice is playing a risky game.


Add to that actively excluding American residents as customers and your right.  Of course that is the hard part.  Just ask Full Tilt Poker how being "foreign" isn't bullet proof when the DOJ starts working with foreign governments to seize assets and secure indictments.  Their servers, records, and 76 bank accounts were not in the United States but that didn't keep them from being seized by the DOJ. http://en.wikipedia.org/wiki/United_States_v._Scheinberg

Since I posted this minutes ago, you clearly had no time to read it carefully. I didn't argue what you said. Read it again.

trade without verification is more, but deposits and withdrawals without verification is less or none.

I added a few more with low volume.

Small update.

have you used ecurrencyxchanga.com to buy btc?
those guys are small but really credible in business.
they have my recommendation always.

Thanks, but that is a trader/seller, this thread is about exchanges, where customers trade between themselves.

Just added www.okcoin.com

So Huobi's new Bitvc doesn't require any verification to trade in cryptos, but they don't offer fiat withdrawals yet, correct?

Yes, you can trade in crypto and chinese renminbi/yuan (so, fiat), but you can only withdraw in crypto.

It seems you can't even try to verify in order to be able to withdraw fiat. You can't in any case withdraw. The site is for traders, not to exchange and withdraw for a bank.

Another update.

check from the list here...
https://bitcointalk.org/index.php?topic=775272.new#new

Thanks, but your list is about exchangers/sellers, not exchanges where one can trade bitcoin with other customers directly.

LakeBTC is also, we can deposit BTC and withdraw BTC, its trading doesn't require authentication. And even no verification you can withdraw fiat via ripple and egopay.
https://www.lakebtc.com/s/help?locale=en#acct_types (https://www.lakebtc.com/s/help?locale=en#acct_types)

Of course, it must be certified via bank wire transfer.

Now as long as no withdrawals by bank wire, you can withdraw fiat on lakebtc.

I believe that you can use cex.io (the market that is behind ghash). You need to verify your identity to withdraw and/or deposit fiat but trading it should not be an issue.

Thanks for your contributions, I'll recheck lakebtc and check cex.io

So Bitstamp is definately out of the question ?

Just looking for a broker where I can sell my BTC for USD and buy it back later when the selling stops.

okcoin now requires account verification for BTC and LTC deposits/withdrawals, at least on new accounts.

Do we need to be verified on Cryptsy to trade now? I get an error when trying to trade crypto to crypto; I've never touched fiat on it:

a red message pops up:

Fiat trading is now live on ExchangeD.I2P -- see:

https://bitcointalk.org/index.php?topic=1092682.msg13889829#msg13889829

What would really be awesome is a list of exchanges who take deposit & withdrawal of crypto AND offer fiat/forex pairs, binary options and classic trading tools like CFD!!

For example Whaleclub offer Margin, Turbo Trading (binary options), and forex trading, BUT their charts are in accurate so don't use them and BE WARNED!

So now all we need is an exchange that offers everything Whaleclub does but doesn't cheat their member by having misleading charts.

Please tell someone knows of such an exchnage?!

Just FYI, the veracity of the list originally posted by OP has changed somewhat.  I think there are now something like just four on that list that actually don't require verification to trade cryptocoins and fiat and withdraw fiat. 

I miss cex.io on the list.
No verification on low volumes.

CEX.io does not count because of this https://support.cex.io/hc/en-us/articles/215744957-Identity-Verification-Guide

There are very few left that will actually let you trade cryptocoins and fiat and withdraw fiat without any verification.  They do exist but they are few in number and you have to seek them out, bearing in mind they could close at any time also.

Making the need for things like Bitsquare, Voluntary.net (Bitmarkets) and Exchanged.I2P all the more vital.

So, as of now what all exchanges are there that don't require any ID for trading crypto?

So there is no exchange out there without any Verification?

Ok, now i say Crypto is a Bubble. The Feds made it possible!