ComplyAdvantage assumes no responsibility for the information contained in this document and disclaims all responsibility with respect to the content or for any action taken on the basis of such information. “Dwyer supported and facilitated BitMEX`s failure to introduce AML (Anti-Money Laundering) or Know Your Customer (KYC) programs, although it closely followed regulatory developments in the U.S. that clearly indicated the legal obligation to do so when BitMEX was operating in the U.S., which it did. DWYER has supported and supported BitMEX`s failure to implement AML or KYC programs, although it has closely followed regulatory developments in the United States that have clearly indicated the legal obligation to do so when BitMEX was operating in the United States, which it has done. DWYER knew that BitMEX`s alleged withdrawal from the U.S. market after or around September 2015 was a deception and that the so-called “controls” bitMEX had put in place to prevent the U.S. Trading was an inefficient façade that did not prevent users from accessing or trading BitMEX from the United States. In addition to its other obligations at BitMEX, DWYER collected and disseminated data proving that BitMEX users included traders and that the company generated revenue in the United States. Cryptocurrencies, digital currencies, and cryptocurrency exchanges are legal in Australia, and the country has been progressive in implementing regulations on cryptocurrencies. In 2017, the Australian government stated that cryptocurrencies are legal and therefore subject to the Anti-Money Laundering and Terrorist Financing Act 2006 (AML/CTF 2006), Section 5 and related rules. Lawmakers have specifically stated that Bitcoin (and the cryptocurrencies that shared its properties) should be treated as property and subject to capital gains tax (CGT).