Exhibit DeskAML · crypto compliance · fraud

Red flag 002 · 9 Oct 2026

Structuring under thresholds

The alert shown is illustrative.

Several transfers, each just under a reporting threshold, that clear it together. FATF lists this structuring among its virtual-asset red flags. We read the FATF list and MASAK's rules for Turkish platforms: the flag is a reason to look, not a verdict.

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Sources

  1. FATF, Virtual Assets Red Flag Indicators of Money Laundering and Terrorist Financing, publication page
  2. FATF, Virtual Assets Red Flag Indicators (PDF)
  3. MASAK, guide for crypto asset service providers on their obligations (2025, PDF, Turkish)
  4. MASAK, guide for crypto asset service providers (May 2021, PDF, Turkish)

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