Disclosure of financial records is another avenue for using production orders, offering a particularly valuable source of information for tracing proceeds and instrumentalities of crime. Anti-money-laundering requirements on banking and non-banking businesses require them to keep specific information about accounts and activity of their customers, which can be extracted and used as a source of intelligence for the identification of assets in question.

In terms of virtual currencies, such inquiries, as already noted above, should be directed to currency exchangers who are supposed to abide by the anti-money laundering requirements, including record-keeping. Information about customers and their transactions in exchange for virtual currencies should be requested in compliance with the applicable data protection standards and used solely for investigation.

Wire transfers are frequently used to exchange fiat money into decentralized virtual currencies such as Bitcoin and vice versa.34 This, as well as other payment methods used by currency exchangers, would be another potentially valuable, documented source of information to focus on in identifying proceeds and instrumentalities of crime.


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