是成为洗钱“帮手”，还是“黑吃黑”渔翁得利，仅在交易所的一念之间。
Whether to become a money-laundering “helper” or a “black-eater” is profitable only in the middle of the exchange.
据财经网·链上财经不完全统计，2019年上半年，全球出现了至少10起加密货币交易所被盗事件，与此同时，数字资产诈骗事件也频频发生。被盗或被诈骗的数字货币总额或已超过了50亿美元。
According to FinCEN & Middot; financial history on the chain is incomplete, there were at least 10 thefts of encrypted currency exchanges around the globe in the first half of 2019, while digital asset frauds were frequent. The total amount of stolen or defrauded digital money was more than $5 billion.
2019年上半年的被盗或被诈骗的数字货币总额较2018年全年上涨194%，较2016年全年上涨733%。
The total amount of stolen or fraudulent digital currency increased by 194 per cent in the first half of 2019 compared to the whole year of 2018 and by 733 per cent compared to 2016.
对于资产持有者而言，一旦链上资产被盗或被诈骗，就难以挽回损失。
For asset holders, it is difficult to recover the loss once the assets on the chain have been stolen or defrauded.
360高级安全专家彭峙酿向财经网·链上财经透露，自己曾处理过几起追回案例，但都是因为作恶者大意留下线索，导致可以被追溯。
360 senior security expert Peng’s stand-off to FCN & Middot; financial disclosure on the chain revealed that he had dealt with several recovery cases, but all because the perpetrators left a trail that could be traced retroactively.
区块链安全公司PeckShield则表示，目前还没有见到完全成功追回的案例。
PeckShield, the block chain security company, stated that there had been no cases of complete successful recovery.
而这些数字资产要想转化为现实世界中的通用法币，大多都需要进入数字货币交易所中进行交易套现。
Most of these figures, however, need to be traded in digital currency exchanges for hedging if they are to be converted into generic French currencies in the real world.
且基于监管、商业信誉以及技术等多种因素，身处套现重要环节的交易所，注定难以置身事外，也难以做出“两全”抉择。是成为洗钱“帮手”，还是“黑吃黑”渔翁得利，仅在交易所的一念之间。
And, based on a variety of factors, such as regulation, business reputation, and technology, an exchange with a critical link is bound to be difficult to stay out of and make a “two-in-one” choice. Whether to be a money-laundering “helper” or a “black-eating” fishery is profitable, only in the middle of the exchange.
2019年被盗或被诈骗数字资产或已逾50亿美元
2019 stolen or defrauded digital assets or more than $5 billion
2019年上半年，BTC由3000美元一路冲高到13900美元，诸多业内人士认为“牛市再次来临”。而随着“牛市”一同来临的，则是各类安全事件。
In the first half of 2019, BTC jumped from US$ 3,000 to US$ 13,900, with many insiders arguing that the “cow market is coming again.” And, along with the “cow city”, it is a variety of security incidents.
曾有报告显示，2018年期间，大约有17亿美元的数字货币被盗或被诈骗，与之相比，2019年的金额更为庞大，波及范围更为广泛。
There have been reports of approximately $1.7 billion in digital currency stolen or defrauded during 2018, compared to 2019, which was larger and broader in scope.
据链上财经统计，截至目前为止，2019年加密货币交易所被盗资产数额已超3亿美元，因加密货币被盗，波兰加密货币交易所Bitmarket，韩国加密货币交易所Coinbin，意大利加密货币交易所Bitgrail相继宣布破产。
According to the financial statistics on the chain, the amount of stolen assets of the crypto-currency exchange in 2019 had so far exceeded $300 million, owing to the theft of encrypted money, the Polish crypto-currency exchange Bitmarket, the Korean-encrypted currency exchange Coinbin and the subsequent bankruptcy of the Italian crypto-currency exchange Bitgrail.
而除了交易所被盗之外，还存在着大量的资金盘项目卷款停服，这些资金盘涉及金额更是庞大。其中仅Tokenstore、Plustoken、波场超级社区三个项目涉案金额就或逾43亿美金。
In addition to the exchange’s theft, there is a large amount of money cut-off on the portfolio, which is even larger. Three projects, Tokenstore, Plustoken, and the super-community at the Dome, alone, are worth more than $4.3 billion.
与法币被盗或被诈骗不同的是，由于数字货币并不是现实世界里的通用等价物，犯罪分子在通过盗取或诈骗等手段获得数字货币之后，还需要将数字货币转化为通用法币。
Unlike stolen or defrauded French currency, since digital currency is not a generic equivalent in the real world, criminals need to convert digital currency into generic French currency when they obtain it through, for example, theft or fraud.
通常将数字货币兑换为法币主要有两种渠道，分别为数字货币交易所交易以及场外OTC，基于犯罪嫌疑人对于匿名性的需求，交易所成为其首要选择。
There are usually two main channels for the conversion of digital currency into French currency, namely, digital currency exchange transactions and off-site OTC, which is the primary option for suspects based on their need for anonymity.
交易所成套现重要环节
exchange set of key pieces
2018年7月，美国区块链反洗钱公司CipherTrace发布了一份报告，报告称，数字货币交易所在洗钱环节中充当着重要角色，大量与犯罪行为高度关联的比特币通过交易所流入了反洗钱监管较弱的国家和地区。
In July 2018, the United States block chain anti-money-laundering company CipherTrace issued a report that digital money exchanges played an important role in the money-laundering chain and that a large number of bitcoins, highly linked to criminal behaviour, were channelled through the exchange to countries and regions with weak anti-money-laundering controls.
这一观点得到了成都链安科技的赞同，成都链安科技向链上财经表示，逃跑资金套现的主要方式为将非法获得的资金转移到各大交易所，再经由交易所提现从而实现套现。
This view was endorsed by the Chengdu chain of peace technology, which indicated to the chain of finance that the main way of running away funds was by transferring illegally acquired funds to major exchanges and then making them available through transactions.
彭峙酿认为，逃跑资金可能利用国内外一些交易所KYC并不严格的漏洞，在国内外多个交易所将数字货币转换、转移多次，最后再到某个交易所进行变现。
The Peng stand-off argues that escape funds may take advantage of the non-strict loopholes of a number of national and international exchanges, both domestic and foreign, where digital currency is converted and transferred several times, and eventually cashed on a particular exchange.
PeckShield向财经网·链上财经补充到，套现交易所并不局限于目前主流的中心化交易所，去中心化交易所也会成为黑客的目标。
PeckShield adds to the financial network & middot; the chain of finance adds that the stock exchange is not limited to the current mainstream centralized exchange and that decentralized exchange will also be the target of hackers.
以近期影响较大的加密货币被盗或被诈骗案例为例，3月底，Dargon Ex因安全漏洞被盗近700万美元，随后被转入ZB、Kucoin、Coinbene等交易所；6月10日，资金盘Tokenstore首次被曝疑似崩盘，同日，PeckShield即监测到Tokenstore资金流入交易所，截至目前为止，Tokenstore的交易所套现之路仍未停止；6月30日10点，波场超级社区的APP正式停止运营，十天后，波场超级社区的部分TRX即被转往币安、火币以及Bitfinex。
In the case of recent cases of the theft or fraud of the most influential encrypted currency, Dargon Ex was stolen at the end of March for nearly $7 million for security holes and subsequently transferred to the ZB, Kucoin, Coinbene and other exchanges; on 10 June, Tokenstore was first exposed and, on the same day, PeckShield monitored the flow of funds into the Tokenstore exchange. Tokenstore's exchange route has not ceased until now; and on 30 June, at 10 a.m., APP for the super-community of the waves officially ceased operations, and after 10 days, part of TRUX for the super-community of the waves was transferred to currency security, tender and Bitfinex.
但是，基于加密货币交易的匿名性以及弱监管的特性，追踪这些资金并非易事。
However, it is not easy to trace these funds on the basis of the anonymity of encrypted currency transactions and the weak regulatory characteristics.
CipherTrace指出，加密货币的匿名性使得追踪加密货币赃款比追踪现金更为困难，而且洗钱者会将非法取得的资金在多个链上地址频繁转移，因此调查人员要想通过网络追查到路径的源头的难度将进一步增加。
CipherTrace noted that the anonymity of encrypted money makes tracing of encrypted money more difficult than tracing cash, and that money launderers often move illegally acquired funds across multiple chains to address them, thus making it more difficult for investigators to trace the source of the path through the network.
PeckShield表示，区块链上追踪跑路资金的困难主要体现在地址追踪和资金冻结两个环节。黑客或者跑路方往往会通过地址中转、混淆的方式来加大追踪的难度，黑客一般会创建若干个账号进行中转，以逃避追踪。即使追踪到一笔脏钱流入交易所，如果不及时通知交易所进行冻结，那么这笔脏钱可能很快会被洗成功。
PeckShield states that the difficulty of tracking running funds on the block chain is mainly due to a combination of address tracing and freezing of funds. Hacking or running parties tend to make tracing more difficult by means of addresses and confusion, and hackers usually create several accounts to avoid tracing.
慢雾安全团队补充到，他们在追踪逃跑资金时发现，很多逃跑资金为了逃离追踪，会对资金进行成千上万次的切割分散，因此溯源的难度很大，而市面上大大小小的交易所也很多，各个交易所之间容易形成情报孤岛，当逃跑资金套现是，情报孤岛之间的信息差就为逃跑资金提供了漏洞。
The slow fog security team added that, in tracking escape funds, they found that many escape funds spread thousands of times in order to escape tracking, making it difficult to trace them, and that there were many large and small exchanges on the market, that it was easy to create information islands between exchanges, and that when escape funds became available, the information gap between them created a gap in escape funds.
此外，事件的突发性也会为追踪带来难度。成都链安科技认为，追踪跑路资金的第一个难点在于跑路具有突发性，多数情况下跑路资金都是由多币种组成的，每个币种都对应多个持币地址，如何在极短的时间内完整的将所有跑路币种的资金地址纳入监控，是要解决的首要问题，且很多项目方在被证实跑路之前就已开始进行资产转移操作。
In addition, the suddenness of the event makes tracing difficult. Chengdu-Sektor believes that the first difficulty in tracking running funds is the suddenness of running roads, which in most cases consist of multiple currencies, each of which corresponds to multiple currency addresses, the complete incorporation of all running-currency funds into surveillance in a very short period of time, is the first problem to be solved, and many of the projects have started to transfer assets before they are confirmed to be running.
交易所难以置身事外火币双榜首
It's hard for the exchange to be at the top of the double list of foreign currency.
链上财经依照公开信息统计，在2019年上半年影响范围较广的11起安全事件中，被监测到已流入交易所的资金约为5亿元人民币。而这11起案件的涉及金额保守估计约为17亿元人民币，被监测到已流入交易所金额约占其发生总额的30%。
According to open information statistics, in the first half of 2019, of the 11 security incidents with a wider impact, about RMB 500 million were monitored for entering the exchange. The 11 cases involved a conservative estimate of RMB 1.7 billion and were monitored for about 30 per cent of the total number of transactions.
在已监测到的数据中，除去未知交易所占据的32.28%，火币、币安以及ZB位列“接收跑路资金排行榜”前三，其中火币为27.72%，币安为21.91%，ZB为6.11%。
Of the monitored data, excluding 32.28 per cent occupied by the unknown exchange, the first three ranks of the “receipt of running funds” in the currency, currency security and ZB, of which 27.72 per cent were in the currency, 21.91 per cent were in the currency and 6.11 per cent were in the ZB.
（单位：万元）
(In thousands of yuan)
而在转入频次中，火币、币安以及ZB依旧占据前三名，在11起案件的42笔资金流动中，有9笔转向了火币，5笔转向了币安，4笔转向ZB。
On the other hand, the first three were still in the pipeline, with 9 of the 42 movements in 11 cases turning to the tender, 5 to the currency and 4 to the ZB.
值得注意的是，在这41笔资金流向中，没有任何一笔流向了OKEx。有业内人士分析，OKEx一直以合约闻名，现货市场以及OTC做的“并不怎么样”，因此并不适合大额逃跑资金套现。
It is worth noting that none of these 41 financial flows goes to OKEx. There is industry analysis that OKEx has been known as a contract, that the spot market and the OTC are “not very good” and that it is therefore not suitable for large-scale flight funds.
而无论是在金额上，还是在次数上，火币均位列第一。有业内人士分析，火币之所以如此受青睐，主要是因为相较于现货市场不够活跃的OKEx以及OTC渠道不够畅通的币安相比，现货市场活跃且OTC渠道畅通的火币成为了最优选择。
In both amounts and numbers, it is ranked first. In some industries, it is analysed that it is so favoured, mainly because the active spot market and the open currency through which the OTC channels operate are the best option compared to the less active OKEx and the less accessible currency through which the spot market operates.
经公开消息整理，上述资金中有一部分已被追回，但是更多的则是已被成功套现或被交易所冻结。据PeckShield透露，TokenStore 跑路资金就有部分被火币、币安、ZB等其他交易所进行了冻结。
According to PeckShield, part of TokenStore’s running funds have been frozen by other exchanges, such as the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, the Democratic Republic of the Congo, and the Republic of the Congo.
而在现行监管体系不完善的情况下，对于交易所而言，成为逃跑资金出口并不是一件安全的事。据一份公开的裁判文书可知，在2014年一起洗钱犯罪活动中，OKEx的前身OKCoin被法院判定为未履行反洗钱义务，并进行了相应处罚。
In the case of a money-laundering offence in 2014, OKEx’s predecessor, OKCoin, was found by the court to be in non-compliance with its anti-money-laundering obligations and punished accordingly.
但是交易所自行冻结资金，又将致使交易所陷入“黑吃黑”的怀疑之中。
However, the exchange's own freezing of funds would put the exchange in a state of suspicion.
据计算，2019年上半年转入火币的逃跑资金额约为其2019年第一季度总收入的1.19倍，转入币安的逃跑资金额约为其2019年第一季度盈利的1.06倍。而ZB未在任何公开渠道透露其收入水平，据非小号数据显示，ZB的交易量约为火币的20%，而其所接收的跑路为火币接收总量的22%。
It has been calculated that the amount of escape funds transferred into the first half of 2019 was approximately 1.19 times their total income in the first quarter of 2019 and 1.06 times their profits in the first quarter of 2019. ZB did not disclose its income level through any public channels, and according to non-small data, the amount of ZB transactions was about 20 per cent of the currency, while the route it received was 22 per cent of the total amount received.
各大交易所尚未建立统一处理标准
链上财经经采访发现，目前各个交易所都已经建立起了各自的风险预警机制，当风险资金注入后，交易所将会收到预警并对此做出处理。
Interviews on the chain of finance have revealed that each exchange now has its own risk warning mechanism in place and that when risk funds are infused, the exchange will receive and deal with the warning.
币安联合创始人何一向链上财经透露，币安已建立黑名单预警机制，如果是已经公开的被盗地址、诈骗地址直接转入币安会有预警直接冻结。
The co-founder of the monetary union, who has always been exposed in the chain of money, has established an early warning blacklist mechanism, which would be directly frozen if the stolen address was made public and the fraudulent address was transferred directly to the currency.
而火币公关部则回应链上财经称，对于有洗钱或跑路的钱包地址，火币都有监控，并有专人负责监督钱包资产的变化，一旦有资金流入，会对资产进行控制。
On the other hand, the Ministry of Public Relations responded to the financial statements on the chain that, in the case of wallet addresses with money-laundering or running routes, the money was monitored and that there was a person responsible for overseeing the movement of wallet assets, which would be controlled once the funds were inflow.
Kucoin公关表示，除了与加密货币合规和调查服务提供商合作之外，Kucoin还自研了一套针对用户交易行为的反洗钱分析系统，当系统进行预警是，Kucoin会有专人负责跟进调查。
According to the Kucoin Public Relations, in addition to working with the crypto-currency compliance and investigation service providers, Kucoin has developed a self-researched anti-money-laundering analysis system for user transactions, and when the system provides early warning, Kucoin will have a dedicated follow-up on the investigation.
在采访多家交易所后链上财经得知，当执法部门介入案件后，通常各个交易所在冻结资金后都会按照指示对资金进行划转。但是对于执法部门未介入调查的冻结资金，各个交易所之间尚未建立统一的处理标准。
After interviews with various exchanges, it became clear that when law enforcement intervenes, it is common for each exchange to transfer funds as instructed. However, there is no uniform standard for dealing with frozen funds that are not investigated by law enforcement.
以TokenStore为例，截至目前为止，尚未有任何证据显示Tokenstore已被有关部门立案调查。但无论是火币、币安还是ZB都曾公开表示过已对这一案件的注入资金进行了冻结处理。
TokenStore, for example, there is no evidence to date that Tokenstore has been investigated by the relevant authorities, but neither the money, nor the money, nor ZB have publicly indicated that they have frozen the funds injected into the case.
何一认为币安没有权限自行处理被冻结资金，对于执法部门未介入的案件，币安通常是等待司法流程的结果移交，但是如果冻结3个工作日之后司法部门依旧未介入，币安只能放行。
Where it is believed that currency security does not have the authority to deal with frozen funds on its own, in cases where law enforcement is not involved, currency security usually waits for the outcome of the judicial process to be transferred, but if the judiciary remains absent after the freezing for three working days, currency security can only be released.
火币公关部则表示，目前暂时不方便透露冻结资金的处理方式，但是火币强调，火币将坚持用户第一的原则。
For its part, the Ministry of Public Relations has indicated that it is not in a position to disclose the treatment of frozen funds for the time being, but that it emphasizes that it will adhere to the principle of user first.
而ZB则拒绝对此进行回应。据了解，近期ZB一直都处于“杀猪盘”、“超卖”、“数据造假”以及“恶意做空”等负面质疑之中。
ZB, for its part, refused to respond. It is known that ZB has been under negative scrutiny in recent times, such as “pig-killing”, “overs”, “data counterfeiting” and “malignty emptying.”
有一位不愿透露姓名的业内人士透露，在没有监管介入的情况下，这部分冻结资金通常都是进了交易所的口袋。
One industry agent who did not want to reveal his name disclosed that, in the absence of regulatory intervention, this portion of the frozen funds was usually in the exchange's pocket.
这一说法得到了一位交易所从业人员的证实，没有依照流程进行划转的资金将会被一直冻结在交易所账户中，且不会与正常资金进行隔离处理。
This assertion was confirmed by an exchange practitioner that funds that were not transferred according to the process would remain frozen in the exchange accounts and would not be treated in isolation from normal funds.
Kucoin公关认为，要从公司层面规避挪用冻结资金，企业自律十分重要，任何想要长远发展的企业，都知道挪用冻结资金会对企业产生多坏的负面印象。
According to the Kucoin Public Relations, corporate self-regulation is important to avoid misappropriation of frozen funds at the corporate level, and any enterprise wishing to develop in the long term knows how negative the misappropriation of frozen funds can be for businesses.
2014年，币圈逐渐开始出现在公众视野之中，但是发展至今，依旧伴随着大量的崩盘、诈骗等负面消息。在监管缺失的情况下，让人相信行业内的企业能做到“自律”并不是一件易事。
In 2014, the currency circle began to appear in public view, but development continues to be accompanied by a lot of negative news about crashes, frauds, etc. In the absence of regulation, it is not easy to believe that firms in the industry can “regulate themselves.”
交易所在行业内既当“裁判”又当“选手”的行为历来为人所诟病，美国财政部所属恐怖主义与金融情报办公室的反洗钱部门FinCEN曾表示，加密货币交易所必须纳入反洗钱控制的监管中。
The practice of the exchange being both a “judge” and a “actor” in the industry has traditionally been ill-advised, and FinCEN, the anti-money-laundering unit of the United States Department of the Treasury's Terrorism and Financial Intelligence Office, has stated that an encrypted currency exchange must be included in the control of money-laundering.
但是在行业整体方向不明的情况下，对交易所进行监管并不是一件易事，因此在目前为止，或许真的只有交易所的“企业自律”最有效。
However, regulation of exchanges is not easy in circumstances where the overall direction of the industry is unclear, so it may be true that so far only the exchange's “business self-regulation” has been the most effective.
(财经网链上财经)
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