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Author Topic: Mt.Gox AML/KYC Process Explained  (Read 9726 times)
MtGox_Dylan
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June 08, 2012, 06:28:33 AM
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(Copied from the Trading Discussion forum for greater visibility)

Hi Everyone,

My name is Dylan, and I work in Mt.Gox's Compliance Division. Our division is responsible for handling the Anti-Money Laundering (AML) and Know Your Customer (KYC) activities for Mt.Gox, and we thought some of our users and the wider community might be interested in having an insight into how the whole process works. For those who may not be aware, AML/KYC checks involve us collecting from our users one piece of photographic identification, and one proof of residence document to help us identify you. Once you've read through it all, feel free to post any questions you might have about the process, as I'd be more than willing to answer any you may have.

Why do AML/KYC?

We are often asked both by email and on the forum why Mt.Gox does these checks. To give a very basic explanation of this issue, Mt.Gox handles both Bitcoin and fiat currency (Dollars, Euros, etc.) As a result, we are bound by the laws of Japan and America, along with various international regulations which cover the fiat side of our business. Very similar to how a bank in most countries must be regulated to ensure they are not facilitating money laundering, terrorist financing or the like, we are obliged to follow the same rules.

Whilst we could simply ignore our legal obligations, as a number of smaller, successful exchanges have done in the past, we have found that this invariably causes problems for both us and our customers. By not performing adequate AML/KYC checks, the banks that we must operate through can and have shut down bank accounts, trapping customer funds and causing us a lot of headache. Therefore, we try to follow this process as best as we are able with as little impact to our users as possible.

What does the process involve?

First, we ask you to provide one piece of government issued photographic identification, which is usually either:

  • A driver's license,
  • A passport, or;
  • A military identification card (surprisingly, we have a large number of customers in the armed forces of various countries.)

We then ask you provide some form of proof of residence document, which is an official document issued within the last three months bearing both your name and full street address. For obvious reasons, we cannot accept addresses with PO Boxes. Usually, we receive one of the following:

  • A utility bill,
  • An internet bill,
  • A cell phone or mobile phone bill,
  • A tax return,
  • A residency certificate issued by your local government,
  • A voting registration form, or;
  • A medical insurance bill

Whilst many of our users submit bank statements as their proof of residence, we unfortunately cannot accept bank statements from our customers. This is because it is relatively easy for fraudsters to open an account at a less reputable banking service which does not check the accuracy of a person's stated address. It is then possible to use this bank's statement as a seed to open accounts at increasingly trustworthy establishments without ever having provided proof of residence in the first place.

What does your division do?

The main job of the Compliance Division is to check documents we receive from our customers, and make sure that all of the necessary documents have been submitted, and more importantly, that none of the submitted documents are forgeries. We check submitted documents against our database of received documents, against publicly available sources of information and also put them through advanced image analysis to identify forgeries. This is done to protect both Mt.Gox and our users from fraudulent activity.

What happens if my application is rejected?

If we reject your documents, we will always explain by email what went wrong in the verification process. The top 5 most common causes for rejection are:

  • Not submitting all the documents. Many people only give us a driver's license or passport on their first attempt, without providing any proof of residence. This is the most common reason for rejection, and costs our customers the greatest amount of time in having their accounts verified.
  • Submitting documents which are too dark or low-resolution to read. The second most common cause for rejection, illegible documents cannot be accepted. Usually this is the result of trying to take photos of documents using a webcam or camera phone, where poor low-light performance and grainy / low resolution images are the norm.
  • Providing files in the wrong format. We have a specialised interface for reviewing documents and putting them through image analysis. At the moment, it can only handle files which are either JPEGs, PNGs or PDFs.
  • Submitting a proof of residence document which has a different name on it to the photographic identification. This often happens when a user is still living with their parents, or if a spouse or room mate pays the utility bills. In these cases, a signed, notarised statement that you reside with whoever's name is on the proof of residence will be enough for us to verify you.
  • Submitting documents in non-latin script. Unfortunately, the Compliance Division doesn't have any staff who can read Cyrillic, Korean, Arabic or Hebrew. As a result, when we receive documents in these languages we must ask our customers to provide English translations of them.

Please note that even if you are rejected the first time around, there is nothing wrong with this - we will keep working with you until we are able to get you verified.

Myths and rumours

I'd like to address some myths and rumours that have sprung up surrounding our AML/KYC process, just to allay any fears people might have about our mysterious need to harvest everyone's identity.

Mt.Gox sells personal information to the DEA

If we were going to sell your personal information to a law enforcement agency, it probably wouldn't be to the American Drug Enforcement Administration. We would make much more money selling it to our local Tokyo Metropolitan Police, since we wouldn't be losing any money on the currency conversion. This rumour probably sprung up because of an interview our CEO (MagicalTux for those on the forums) gave some time ago, where he mentioned sending a letter to the DEA explaining what Bitcoin was. This was back when a certain American Senator was investigating Bitcoin over the growing popularity of Silk Road.

We invite our users to read our privacy policy and repeated posts on the forums where we state that we will only provide your personal documents when legally required to do so. This will usually involve law enforcement agencies issuing us a court order compelling us to release an individual's information and is a very rare event even in the fiat banking world.

Mt.Gox makes money from personal identification some other way, like selling it to advertisers

While it would be a great income stream for us, sadly we are not legally allowed to sell your personal information. This is both because of our privacy policy, and because we are based in Japan, a country with some of the strictest privacy laws in the world. In fact, hiring staff to fill our Compliance Division, hosting and securing an extremely large amount of image data and carrying out the AML/KYC process is one of our more significant company expenses.

So while we'd love to be able to offset the costs a little, if we were ever caught doing this as a company, we would face serious fines and even jail time. We hope that knowing that this threat to us exists gives you confidence that we're being kept honest.

Mt.Gox has stricter AML/KYC requirements than other companies

This is actually true, in some cases. For example, before Dwolla changed their terms of service they allowed some users to become verified with only a driver's license, or only a proof of residence document. While we truly regret that we must ask for as much documentation as we do at Mt.Gox, we are providing services to users internationally in Europe, America, Russia, South-East Asia and elsewhere, and as such have to meet the harshest requirements of all of the countries we operate in.

Many of our German and Polish users have probably experienced a great deal of frustration getting verified with Mt.Gox, as Germany and Poland both issue an identity card which includes a person's current address. Unfortunately, because we must also follow American and Japanese rules, we also have to ask for separate proof of residence documents.

Conclusion

I hope you found my post interesting, or at least informative. If you have any questions about our process, please feel free to either PM me or post here and I'll be sure to answer! If you have a question about your specific application to become verified, please email our AML email address so we can maintain the confidentiality of your application.
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June 08, 2012, 06:30:45 AM
 #2

(Copied from the Trading Discussion forum for greater visibility)
Yeah... no, that's not how it works...
MtGox_Dylan
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June 08, 2012, 06:35:38 AM
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I know, but honestly this will have the biggest impact on new Mt.Gox users who are far more likely to come here than the Trading Discussion sub-forum. I hope the mods will show a little leniency on this one, but if not that's quite understandable.
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June 08, 2012, 11:55:50 AM
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Why do AML/KYC?

 Mt.Gox handles both Bitcoin and fiat currency (Dollars, Euros, etc.) As a result, we are bound by the laws of Japan and America, along with various international regulations which cover the fiat side of our business. Very similar to how a bank in most countries must be regulated to ensure they are not facilitating money laundering, terrorist financing or the like, we are obliged to follow the same rules.

Oh please enough with the state propaganda bullshit.

Why don't you tell it like it really is. You are not obliged, you are forced under threat of violence to gather information about your customers so that governments around the world can control what your customer's money is being used for. "Money laundering, terrorist financing or the like" are victimless crimes the state invented as a way to gain even more control over the people they assert their rule over.

You can't imagine the angry thoughts that go through my mind when I read bs propaganda like this, I'm pretty sure if they already tried to attack people for thought crime I'd get the capital punishment.  Angry

My personality type: INTJ - please forgive my weaknesses (Not naturally in tune with others feelings; may be insensitive at times, tend to respond to conflict with logic and reason, tend to believe I'm always right)

If however you enjoyed my post: 15j781DjuJeVsZgYbDVt2NZsGrWKRWFHpp
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June 08, 2012, 12:01:05 PM
 #5

http://bitcoin-otc.com/  ftw

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June 08, 2012, 12:08:38 PM
 #6

Why do AML/KYC?

 Mt.Gox handles both Bitcoin and fiat currency (Dollars, Euros, etc.) As a result, we are bound by the laws of Japan and America, along with various international regulations which cover the fiat side of our business. Very similar to how a bank in most countries must be regulated to ensure they are not facilitating money laundering, terrorist financing or the like, we are obliged to follow the same rules.

Oh please enough with the state propaganda bullshit.

Why don't you tell it like it really is. You are not obliged, you are forced under threat of violence to gather information about your customers so that governments around the world can control what your customer's money is being used for. "Money laundering, terrorist financing or the like" are victimless crimes the state invented as a way to gain even more control over the people they assert their rule over.

You can't imagine the angry thoughts that go through my mind when I read bs propaganda like this, I'm pretty sure if they already tried to attack people for thought crime I'd get the capital punishment.  Angry
You can't imagine the angry thoughts that go through my mind when I read this bullshit libertarian and anarchistic off-topic propaganda.
just because you a little afraid kid, paranoid about the big bad government, that is actually trying to make you safe and comfortable, you don't have to spray your fuck system shit around this forum at all time.

"The whole problem with the world is that fools and fanatics are always so certain of themselves and wiser people so full of doubts." -Bertrand Russell
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June 08, 2012, 12:18:11 PM
 #7

Why do AML/KYC?

 Mt.Gox handles both Bitcoin and fiat currency (Dollars, Euros, etc.) As a result, we are bound by the laws of Japan and America, along with various international regulations which cover the fiat side of our business. Very similar to how a bank in most countries must be regulated to ensure they are not facilitating money laundering, terrorist financing or the like, we are obliged to follow the same rules.

Oh please enough with the state propaganda bullshit.

Why don't you tell it like it really is. You are not obliged, you are forced under threat of violence to gather information about your customers so that governments around the world can control what your customer's money is being used for. "Money laundering, terrorist financing or the like" are victimless crimes the state invented as a way to gain even more control over the people they assert their rule over.

You can't imagine the angry thoughts that go through my mind when I read bs propaganda like this, I'm pretty sure if they already tried to attack people for thought crime I'd get the capital punishment.  Angry
You can't imagine the angry thoughts that go through my mind when I read this bullshit libertarian and anarchistic off-topic propaganda.
just because you a little afraid kid, paranoid about the big bad government, that is actually trying to make you safe and comfortable, you don't have to spray your fuck system shit around this forum at all time.

+1

Some people on this forum are truly paranoid about anything government related...

www.bitbuy.nl - Koop eenvoudig, snel en goedkoop bitcoins bij Bitbuy!
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June 08, 2012, 12:20:34 PM
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the big bad government, that is actually trying to make you safe and comfortable

By robbing me of 40-50% of what I earn and by threatening me with violence and even death if I don't follow it's arbitrary rules to the letter? Yeah fuck that type of a protection, I didn't ask for it and I would never be stupid enough to ever do so.

My personality type: INTJ - please forgive my weaknesses (Not naturally in tune with others feelings; may be insensitive at times, tend to respond to conflict with logic and reason, tend to believe I'm always right)

If however you enjoyed my post: 15j781DjuJeVsZgYbDVt2NZsGrWKRWFHpp
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June 08, 2012, 12:24:13 PM
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Do a US issued driver licenses with printed addresses qualify as proof of residence?
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June 08, 2012, 12:28:07 PM
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Why do AML/KYC?

 Mt.Gox handles both Bitcoin and fiat currency (Dollars, Euros, etc.) As a result, we are bound by the laws of Japan and America, along with various international regulations which cover the fiat side of our business. Very similar to how a bank in most countries must be regulated to ensure they are not facilitating money laundering, terrorist financing or the like, we are obliged to follow the same rules.

Oh please enough with the state propaganda bullshit.

Why don't you tell it like it really is. You are not obliged, you are forced under threat of violence to gather information about your customers so that governments around the world can control what your customer's money is being used for. "Money laundering, terrorist financing or the like" are victimless crimes the state invented as a way to gain even more control over the people they assert their rule over.

You can't imagine the angry thoughts that go through my mind when I read bs propaganda like this, I'm pretty sure if they already tried to attack people for thought crime I'd get the capital punishment.  Angry
You can't imagine the angry thoughts that go through my mind when I read this bullshit libertarian and anarchistic off-topic propaganda.
just because you a little afraid kid, paranoid about the big bad government, that is actually trying to make you safe and comfortable, you don't have to spray your fuck system shit around this forum at all time.

I agree, can we leave the libertard propaganda out of a factual discussion like this? Go to Politics & Society and rant there. I don’t need to read the "TAXATION IS THEFT! INFLATION IS THEFT! AT GUNPOINT!" in such a thread.

Your kind is the worst possible publicity for Bitcoin.

"Bitcoin had been transformed from an anarachistic challenge to the financial status quo, to the crypto spawn of Satan, fuelled by cut-throat greed and delusions of avarice." - MatTheCat
"these people don't seem to want to stop till Bitcoin is completely destroyed and left like an old cum rag in the corner of the room." - ShroomsKit
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June 08, 2012, 12:30:54 PM
 #11

Those of you saying I should STFU, I have a question:

If my comments aren't the truth, why are you so pissed about them, can't you just ignore me? Or does it hurt too much to be faced with the facts of reality for you to be able to do so?

I know, I know, cognitive dissonance is a bitch.  Roll Eyes

My personality type: INTJ - please forgive my weaknesses (Not naturally in tune with others feelings; may be insensitive at times, tend to respond to conflict with logic and reason, tend to believe I'm always right)

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June 08, 2012, 12:35:03 PM
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Those of you saying I should STFU, I have a question:

If my comments aren't the truth, why are you so pissed about them, can't you just ignore me? Or does it hurt too much to be faced with the facts of reality for you to be able to do so?

I know, I know, cognitive dissonance is a bitch.  Roll Eyes
i like to live in my truth-free but happy little world.

(congratulation you just won a click on the ignore button)

"The whole problem with the world is that fools and fanatics are always so certain of themselves and wiser people so full of doubts." -Bertrand Russell
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June 08, 2012, 12:36:00 PM
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Yeah, ignorance is bliss.

My personality type: INTJ - please forgive my weaknesses (Not naturally in tune with others feelings; may be insensitive at times, tend to respond to conflict with logic and reason, tend to believe I'm always right)

If however you enjoyed my post: 15j781DjuJeVsZgYbDVt2NZsGrWKRWFHpp
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June 08, 2012, 12:37:22 PM
 #14

Are US issued driver licenses with printed addresses qualify as proof of residence?

This was answered in the other thread... This is why making two threads is a bad idea...

damn, now i have to go dig for an answer in another thread :-/
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June 08, 2012, 12:44:48 PM
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+1 for the explaination of your processes.
To bad Bitcoinica can not do the same  Cry

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June 08, 2012, 12:58:20 PM
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Ok, so far the not-so-much news about what you state why and what for you need all that info on users.

Now I am much more interested what flags the KYC on users, which freezes their account and funds until they comply? I refuse to comply to your KYC policy. What is the max amount of combined funds I may have? What kind of "suspicious transfers" (?!?) will flag me?

Being able to calculate the risk on MtGox would be a plus, and may keep me from going to another exchange like Intersango.

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June 08, 2012, 01:13:20 PM
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Ok, so far the not-so-much news about what you state why and what for you need all that info on users.

Now I am much more interested what flags the KYC on users, which freezes their account and funds until they comply? I refuse to comply to your KYC policy. What is the max amount of combined funds I may have? What kind of "suspicious transfers" (?!?) will flag me?

Being able to calculate the risk on MtGox would be a plus, and may keep me from going to another exchange like Intersango.

Ente

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June 08, 2012, 01:59:23 PM
 #18

(Copied from the Trading Discussion forum for greater visibility)
Yeah... no, that's not how it works...

Thanks, tt. Your post brought to my attention that the OP stemmed from another section, so I went there first. But now I'm in a dilemma--where to post. It seems both have identical OP's, and both are currently getting commented on. The author, Dylan (what the hell did I just find while getting the URL of his user name?), did a fine job penning said post, using American English, but didn't have the foresight to realize that posting in two different sections at the same time, with exact OP, would only cause confusion unless, of course, that's the intent.

I guess I'm capable of only posting on this thread, my questions and concerns, importing quoted posts from the other thread. FUCK ME!!! After typing that, I realized that that may not work either, for it would continue to fork the timeline, creating a bigger mess everyone would have to walk through. Then again, maybe I'm just over thinking this.

That said, my first question, with many more to come. How strict does Mt. Gox abide by the following?

Quote
By opening an account to use the Platform ("Account") Members represent and warrant:
  • they have accepted these Terms; and
  • they are at least 18 years of age and have the full capacity to accept these Terms and enter into a transaction resulting on the Platform

<tinfoil hat on>I just realized that when you posted this, it was about 3PM in Japan, with your last log-in at 7PM (Japan time), and now the weekend is coming up. Are you planning on working over the weekend, thus getting paid overtime (not sure how that works over there), addressing questions and concerns (now on two fronts) of which you've stated in the OP(s) that you would do? But that's not why my TFH is on. I simply find it odd that these threads where created immediately after I posted here (see timestamp).<TFH off>

When answering my question, you might as well make your answer as thorough as possible, for any vague answer will surely be followed up with more questions relating to this now very important age issue thingy.

~Bruno~

EDIT: I just realized something else. Dylan started both thread prior to begin addressing any questions or concerns. I believe that this was planned beforehand, knowing that the weekend was coming up, coupled with having these up to possibly take focus away from some other issue(s).
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June 08, 2012, 02:04:52 PM
 #19

Why do AML/KYC?

 Mt.Gox handles both Bitcoin and fiat currency (Dollars, Euros, etc.) As a result, we are bound by the laws of Japan and America, along with various international regulations which cover the fiat side of our business. Very similar to how a bank in most countries must be regulated to ensure they are not facilitating money laundering, terrorist financing or the like, we are obliged to follow the same rules.

Oh please enough with the state propaganda bullshit.

Why don't you tell it like it really is. You are not obliged, you are forced under threat of violence to gather information about your customers so that governments around the world can control what your customer's money is being used for. "Money laundering, terrorist financing or the like" are victimless crimes the state invented as a way to gain even more control over the people they assert their rule over.

You can't imagine the angry thoughts that go through my mind when I read bs propaganda like this, I'm pretty sure if they already tried to attack people for thought crime I'd get the capital punishment.  Angry
First and foremost, don't let the bullies in this thread silence you (and shame on them).  Your opinion is just as important as mtgox trying to work within the current system.

I think we have to view the situation for what it is…mtgox is trying to operate out in the open and within the confines of the existing law…whether that law is legitimate or not.  At BitPay, we do the same.  Above a certain threshold and we require identifying information before we'll process transactions.  We even turn away many merchants trying to sell things of questionable legality (they really shouldn't even be considering use of a third party processor like us in the first place).  Some of these merchants are already accepting payment from paypal or visa/mc.  As a libertarian, I don't agree with the prohibition and criminalization of drugs, yet we have to turn away those businesses.  As a Bitcoin business, you really have to make a decision, either you operate in the open and comply with the existing laws, or you completely mask yourself (as Silk Road has done).  There's really no middle ground.  Any business trying to operate in a middle ground is going to fail.

The reality is that money is information and, like any other form of information, it can be sent anywhere in the world in the blink of an eye and in complete privacy.  Many of the laws governing money simply ignore this basic reality and that's a dangerous situation that we must work to change.  People have to come to terms with the idea that financial transactions need to be allowed to be private if we value freedom at all.

Law enforcement has become accustomed to using the financial system to catch criminals, but this is only a relatively recent phenomenon.  It wasn't that long ago that the world didn't have computers or the Internet and the world still turned and law enforcement still managed to do their job.  We need to acknowledge that innovations around money are likely to take this tool away (Bitcoin or no Bitcoin) from law enforcement.  While I don't agree with all laws, I do agree with the concept of laws.  While I may not believe we need a government that consumes (and largely wastes) 25% or more of our economy, I do believe that even in a completely anarchistic society, we need a legal structure and we need law enforcement.

So, back to mtgox and Bitcoin businesses operating in the open in general…voices like yours are very important and highly valued.  You express an opinion that even people running businesses that try to remain in compliance with laws largely agree with.  These businesses need your voice and voices like yours in order to have a dialog with regulators that moves things in the right direction.  The thing I fear most is that Bitcoin and software like bitcoin will be banned.  I don't fear the collapse of Bitcoin, Bitcoin was designed to be unstoppable.  I fear it because I fear what such a course of action means for the fabric of society.  I fear what would happen when governments collapse.  I know some people believe that's inevitable and that we simply have to brace ourselves and manage the best we can.  I don't think it necessarily has to go that way, but we do need people that can listen and can understand.  

It's not even so much about ideology as it is about acknowledging reality.  Unfortunately for mtgox, BitPay and others, we may find that the market ultimately just routes around us.  The regulators might like the fact that mtgox is collecting all this information, but that's not going to do regulators any good when their volume is 0.

(gasteve on IRC) Does your website accept cash? https://bitpay.com
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June 08, 2012, 02:15:02 PM
 #20

Well shit, so now I have to post this in two places because I don't know which thread is being monitored:

Thanks for the post MTGox_Dylan.  I think most everyone was already aware of these FAQ points, though.  That has never really been the issue, so I'm not sure what is hoped to have been accomplished by making this post, other than as a distracting measure (This would have been perhaps more effective: http://chanarchive.org/content/1_b/378881354/1328366326840.jpg).

The real problem here is, as has already been at least partially mentioned:

1. The lack of transparency in the process.
2. The lack of communication.
3. The lies and false promises made by MTGox Support Staff with regards to AML/KYC.
4. Delay after delay, ostensibly under the guise of AML.
5. The just plain ludicrous decisions (Goat as an example).  Perhaps transparency would clear these up.
6. The fact that most decisions made by MTGox seem completely arbitrary, and nothing... NOTHING pisses off customers more than arbitrary decision making.  When your actions are not predictable in a given situation, you are wrong.  Period.

So while this post is nice and all, I'm not sure what you're hoping to accomplish other than to distract from the real issues surrounding MTGox.  My situation, that has been on going since April, is still unresolved.  I am not the only one in this situation and there are plenty of others in similar situations. 

Again, this does not seem to be an AML issue, it seems to be an insolvency issue.  MTGox is unable to fund even moderate sized fiat conversions, which leads many of us to believe you guys are basically bankrupt and a disaster waiting to happen.  The fact that no one has publicly denied this (not that we'd believe you at this point anyway, given MTGox track record of lies and falsehoods) certainly does not bolster confidence in MTGox at all.

Maybe this is the wrong thread to bring any of this up, but I don't want people to be distracted by this kind of thread from the real issue of MTGox being unable to meet their obligations to even moderate sized customers, especially when you are trying to gain new customers who will end up completely screwed when the Gox house of cards comes crashing down.

If you're searching these lines for a point, you've probably missed it.  There was never anything there in the first place.
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