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Debanking (and Debunking?)
Crypto advocates kicked off a recent, somewhat politicized, discussion of debanking. Strap in for scintillating banking compliance trivia.
When a regulator publishes position papers that it wants you to do something, and reiterates this in individualized supervisory guidance, that tends to create a perception in this author that the communicated policy direction was not YOLOed onto the Internet by a room full of monkeys banging keyboards randomly. Ryan Salame, a subject matter expert in laundering crypto money through the banking system (skills described by his lawyers, see pg 7 and onwards), tweeted that it beggars belief that Silvergate did not know that Alameda Research and North Dimension were in fact receiving FTX customer funds flow. You could “brigade” those automated tools (e.g. act in concert with friends to mass report a social media post), or make a fuss on Twitter (and wait for a company to perceive brand risk), or just ask an individual Trust and Safety person at a party.
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