Mariano (Nano) Gemignani

Describe your role in Argentina’s FIU and what drew you into the world of crypto investigations.

I provided technical assistance to judges and prosecutors within the context of complex AML investigations. My caseload involved human trafficking, complex tax evasion, drug trafficking and terrorist financing. I also assessed suspicious activity reports (SARs) and collaborated with FIUs in other countries as part of cross-border investigations.

As I occasionally encountered crypto-related cases, I began studying the basics of blockchain and understanding how it could be leveraged to investigate illicit financial flows. I was immediately intrigued by the ability to analyze a transaction on any public explorer without needing to subpoena an entity, such as a financial institution, to obtain relevant records.

How did working at Bitpanda change your perspective? What did you learn from a compliance standpoint?

An effective, proportionate crypto compliance program requires solid functional knowledge of how blockchains operate. Policies that are developed without this practical understanding are unlikely to be fit for purpose!

Working at Bitpanda – on the frontline of crypto – gave me an operational insight into blockchain functionality. My initial focus was transaction monitoring – scrutinizing both fiat and cryptocurrency transactions that had been flagged as potentially high-risk. I later joined Bitpanda’s risk team, and deepened my understanding of how illicit actors interact with exchanges, what the different risks are, and how to mitigate them effectively.

Above all, I learned to appreciate the delicate balance between an exchange’s operational features and the guiding principles behind decisions to block transactions.

What cases have you worked that held particularly formative lessons for you as an investigator?

While in Argentina’s FIU, I worked on a high-profile, very complex and intricate tax evasion scheme, which involved many national agencies. It really taught me the value of perseverance and collaboration. Initially, the investigative hypothesis seemed almost impossible to confirm, due to the sheer breadth of the case. However, working constructively with other agencies, we were able to reach the burden of proof required to arrest the perpetrator.

Later, at Bitpanda, I tracked a group of customers attempting to abuse the platform for illicit purposes. While the group’s initial tactics were easy to detect, they became more sophisticated over time. I learned that adaptability – particularly having the perspective to stand back and reassess your approach – is a key skill for investigators. That is what enables us to keep pace with, and ultimately disrupt, evolving criminal tactics.

Another lesson is the importance of language skills. Being a native Spanish speaker has been essential in working on many complex investigations because illicit actors operate across several jurisdictions. With transactions happening 24/7, the ability to communicate quickly and accurately in multiple languages can be very helpful, as time is of the essence.

What are the biggest challenges you have faced as an investigator? How have you addressed these?

In the early days, any investigation that was crypto-related was a challenge in and of itself. Only being able to trace transactions though block explorers – without attribution – was incredibly time-consuming in complex investigations. It was also diametrically opposed to the fast-moving, instantaneous nature of the blockchain transactions themselves!

As criminals started moving away from Bitcoin, lacking a tool to track and analyze transactions on the Ethereum blockchain made it that much harder to extract valuable intelligence. Often it meant we were unable to close the knowledge gap between what we could see on-chain and the actors behind the transactions.

Well-designed blockchain analytics tools are transformative for investigators. For me, having access to TRM Forensics – with its multi-chain tracing ability – made a real difference. The tool’s “detect” feature – whereby you are notified as soon as one of your addresses of interest sends or receives funds – can give an investigator a real headstart and the opportunity to trace in real time, which is vital for incident response cases. Other standout features include its ability to track unplotted flows and cross-chain swaps.

Can you recall an example of when your collaboration with law enforcement transformed a case?

Soon after joining TRM, I assisted a law enforcement partner with a case into suspected cryptocurrency laundering. The investigator had received a reply from a VASP that contained tons of information, but he was struggling to extract value from it.

To help, I used TRM Forensics to trace the transactions and addresses he had provided. Information I gathered signaled the existence of what appeared to be an organized criminal group, whose various members had distinct roles. The information allowed the investigator to ask the prosecutor overseeing the case to bring charges against the individuals. It was extremely rewarding that our input provided the final piece of that investigative puzzle!