Surveillance Finance 101 with Seth Hertlein and Michael Mosier

Sep 12, 20231 min read

Seth Hertlein, VP Global Head of Policy at Ledger, and Michael Mosier, Co-Fouder of legal boutique Arktourous, Build Exante - FinCEN, Treasury, and Chief Technical Counsel at Chainalysis join us on today’s show to explain the modern financial surveillance apparatus. FATF, FinCEN, AML/KYC, OFAC...the blacklists, the greylists. How does it all work? Who makes the rules?


0:00 Intro

9:10 Financial Surveillance

13:10 Data Collection

17:10 The Bank Secrecy Act

20:30 SARS

23:10 Understanding the Enforcers

30:30 Goals for FINCEN

38:55 OFAC Explained

51:11 Strict Liability

56:26 Process of Getting OFAC SDN List

1:00:50 Tornado Cash

1:11:05 What Should We Do?

1:21:05 Closing & Disclaimers


Michael Mosier


Seth Hertlein


Not financial or tax advice. This newsletter is strictly educational and is not investment advice or a solicitation to buy or sell any assets or to make any financial decisions. This newsletter is not tax advice. Talk to your accountant. Do your own research.

Disclosure. From time-to-time I may add links in this newsletter to products I use. I may receive commission if you make a purchase through one of these links. Additionally, the Bankless writers hold crypto assets. See our investment disclosures here.

Account Light mode Log Out