SEPA Seller Name is an Exchange URL

Hi, I am this exchange.
We are a small legal BTC trading company from Poland (similar like other European entities we can trade legally after Directive AMLd5 from 1st January 2020 - Bitcoin trading is officially possible for all citizens and companies in the EU).
Why I should to resign from giving the market making on Bisq? Many our trading peers said that it is a good thing that we are active here, we don’t make dumping, we use standard prices (betweeen +1.79 and +3.51%).

In SEPA system each trader must present his indentifiers, to make the wire transfer.
If you don’t want to make this - please don’t use SEPA system simply. Then you will lost your privasy - the banking system will have your data nad your trading peer.
SEPA EUR is not a crypto simply.

Well, that’s news for me. I guess we need to update Bisq’s guidelines. These are the current rules. @lorilorilori @FlyingAtomPL is there anything that you think that should be changed/updated?

@huey
Sure, I’ll take a look into this in about 5-6 hours, to verify what can be added (if anything is needed) after AMLd5 directive in the EU from 1st Jan 2020.

I’m not exactly sure why you bring up AMLd5 as it specifically says that being a crypto exchange you fall under full EU AML obligations. How are you ensuring AML being done when trading on Bisq?

If I where op I would be equally unhappy, wouldn’t want to transact with any exchange here on Bisq. Privacy being: if your bank smells anything crypto related they close your bank account, no questions asked. That’s a reality in most cases. What excuse will you give if it’s bloody url in the sellers name.

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Yesterday I called for support exposing my concerns that this is not an individual person and that this could be some kind of elaborated scam.

My point of view was:
"Supose the person on the other side of my trade is not the Exchange owner, but a scammer.
Once I sent the deposit, they knew my name and my bank account number.
They could have just created a false account with my data at the Exchange.
If I send the SEPA transfer to the exchange account, the exchange would assign that money to the newly created account with my name.
So the scammer would be at charge of that money and can buy BTC and send it to their personal wallet."

This was the mediator response:

“well we are all ‘exchange operators’ as users of the bisq exchange network, while most are individuals some are also using business accounts… just because you recognize the name of someone that doesn’t mean anything special. however, you do raise some good points, I will ask the other trade party to verify to me they are actually part of that exchange, but you can’t really cancel a bisq trade unless both parties agree or there is some proof of fraud. i will investigate”

“your trade counterparty proved to me that they are affiliated with the XXXX exchange, I sent them an email there and they were able to confirm the contents, so I don’t see any evidence of fraud. so… you are obligated to complete the trade using the bisq trade protocol as agreed by the parties.”

So I was obligated by the mediator to complete the trade.

I sent the payment, and I hope everything ends well, but I’m not satisfied at all.

I was obligated to trade with an exchange I would have never voluntarely chosen, and for me this defeats entirely the purpose of bisq.

I have nothing against the people at the other side of my trade (the Polish Exchange), probably they are honest people involved in promoting bitcoin, but I came to bisq seeking privacy, if I’ve wanted to buy at an Exchange I would have gone to Kraken which has lower prices and is much more fast and convenient than bisq.

As I said, I hope this trade ends well, and I’ll receive soon the BTC I’ve paid for, but I also like the bisq team to think a solution to this case and apply a fix to avoid this kind of unwanted trades to happen in the future.

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@lorilorilori
So easy to say “a scammer” about anyone…
In this way we can name each our next trade peer, and such behaviour can be simply a waterfall. Better is to discuss earlier the situation in details, then to use the name “scammer” if needed.

By the way, I don’t understand your arguments, because you use SEPA transfer and you want to see privacy in Bisq.
Don’t use SEPA, then no your private data will be published. But if you use SEPA, all your personal data for your trading peer aren’t private anymore.
Also if you trade with anyone on Kraken, then also your trading peers don’t know about your personal data. So, by using your arguments, trading on Kraken is more private than on Bisq.

For me Bisq is decentralized trading system, not private in fiat. Everything is registered in blockchain, simply what we have looked for many years, apart from centralized exchanges. But by using fiat in Bisq you cannot be private for anyone, because you use your personal data in wire transfers. This is my point of view.

But naturally, if any new rules of Bisq are “you cannot be a company” then we will stop our activity on Bisq, that’s obvious.

@bombo
There is a lot of legal materials at this subject with description how to make it in a proper way.
Especialy this is made with some rules, like under 15k EUR and not divided transaction plus OFAC register. But obviously there is more obligations which we have to meet.

@bombo
So if you use SEPA - then any your trading peer can make you a trouble through compliance services in banks.
By the way - in SEPA system a receiver name and address isn’t important. The IBAN account and the reason for payment are important.
So, what I know - you can send a SEPA wire transfer to “Somebody Nnnn” each time when you use SEPA system by using a valid IBAN bank number and the reason for “payment”. It will be delivered to the recipient with your valid personal data, and valid reason for payment. So SEPA allows to prevent you against deconspiracy the recipient, if it is sporadic case. It is your choice.

Changing the recipient name in SEPA is not allowed in bisq, as it may be used for a triangulating scam.

@lorilorilori
SEPA dosn’t provide the whole data of the wire transfer for the recipient, only the sender data, reason for payment and IBAN.
So Bisq says “use the exact name of a sender what is your registration. The recipient has to check the sender’s data, amount and the reason for payment - must be comply with Bisq trade”. There is no possibility in SEPA system to check was the valid name of the recipient used. The transfer simply is going to the recipient.
Obviously as you said - we use always all data in our wire transfers, because we don’t have to mistify anything, we have been on the market for many years, we use AML, so the banks don’t interrupt our activity.

I’m not saying you are a scammer.

I’m saying that the attack vector I’ve written could be used theoretically in a scam.

Yesterday I was 95% sure you were not a scammer, otherwise I haven’t sent the payment.

Edit:
The trade has just finished correctly, so now it’s 100% sure.

@lorilorilori
Thanks a lot for this confirmation that has been delivered. Good trade! Hope, see you soon again in next trade. Naturally if not, we respect of your point of view.

@FlyingAtomPL
Thanks for the trade. To finish I’ll remember you some important information.

Our interaction was exclusively as users of the bisq application/protocol.

I’ve never accepted being a customer of your Exchange, I have not registered at your Exchange and I have not signed any agreement on the conditions of your Exchange.

I also expect you to comply with the European Union GDPR as I’ve never signed anywhere that I give you consent for processing my personal data.

You don’t have my permission to store my personal data at your databases, archives, registries, etc…

You may be in a very big legal problem using a platform like bisq for your trades as a company. It’s up to you to look for good legal advice in this matter.

Goodbye and my best wishes.

@lorilorilori
Sure, we don’t store it. Banking system stores the data, You gave them your data during using SEPA system, which you use it for your reasons. You decided to do it by using SEPA banking system.

@lorilorilori would you please so kind and tell us the Onion address of this Polish exchange ?
I want opt-out in trading with them. But I don’t want discard the Polish basket for one foul apple.

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You can’t opt out of someone taking your offer, merely seeing theirs.

So I have to discard the Polish basket for Sepa transfers. Pity.

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@lorilorilori @AndyCC @huey @bombo
Please see the solution was taken yesterday - on Keybase, in the general discussion.
This solution is an open and healthy step for everybody, to make trading on Bisq is better in the future.
So don’t discard Polish basket, FlyingAtomPL has changed the activiy on SEPA in Bisq, after rational discussion yestereday.

I think this is a serious issue. Moderators, Mediators and developers should revise their stance on this. Below is my reasoning and proof.

The banks is some countries, keep a kind of blacklist/greylist of IBAN accounts. Usually these IBANs belong to Crypto Exchanges or businesses that are Crypto related. Transfers going out to these IBANs are sometimes completely blocked or in some cases monitored/reported to the authorities (tax authorities usually). People sending to the blacklisted/greylisted IBANs usually get flagged. I would not be surprised if some banks would go even further to close their clients’ accounts, based on the “evidence” that the clients sent -or tried to send- a transfer to a blacklisted IBAN.

To support my claim, I am posting below a screenshot of the bigest bank in Greece completely blocking a transfer to an IBAN belonging to Kraken. The block occurs even before the transfer is actually initiated!
IBAN-Discrimination

For those we don’t understand Greek, here is the actual text, if you want to pass it to an online translator:

ΠΡΟΣΟΧΗ: Πιθανό πρόβλημα στην επικοινωνία. Εάν πραγματοποιήσατε συναλλαγή παρακαλούμε ελέγξτε τις κινήσεις και το υπόλοιπο του λογαριασμού σας προτού προβείτε σε επανεκτέλεσή της.

Ο ΛΟΓΑΡΙΑΣΜΟΣ DE31700222000071788512 ΕΙΝΑΙ ΜΠΛΟΚΑΡΙΣΜΕΝΟΣ

Pay special attention to the last sentence is caps where the useful information is.

We all know this is considered an IBAN discrimination and is not allowed (see h++ps://ec.europa.eu/info/law/single-euro-payments-area-regulation-eu-260-2012/monitoring-and-enforcement_en for details). But they do it nonetheless. Remember that not all countries operate with the same rules and don’t enjoy the same freedoms.

It has also come to my attention that people face similar issues when receiving SEPA transfers coming from certain IBANs, belonging to exchanges. The transfers are either delayed, blocked, returned, flagged, reported to the authorities, or a combination of these.

Why should bisq care?
Multiple reasons:

  1. Bisq users should have a choice to avoid the trouble their bank might cause them, when their bank flags a SEPA transfer coming in from or going out to an exchange
  2. Some trades will not be able to complete, since some banks are blocking SEPA transfers to Crypto exchange IBANs (case when Bisq users want to use their bank accounts to buy crypto in Bisq and they happen to have traded with an exchange without knowing it)
  3. Some trades will take a very long time to complete, since some banks are delaying (or blocking until you provide them extra documentation), or even just return SEPA transfers coming from Crypto exchange IBANs (case when Bisq users want to use their bank accounts to sell crypto in Bisq and happen to have traded with an exchange without knowing it)
  4. I expect that more banks will engage in such bad (and unlawful) behavior in the future, before things start to get better.
  5. Increase the number of mediation requests (and ofc unhappy users of Bisq)

What I think Bisq developers should do
Bisq should not block exchanges. Instead, request exchanges to note this information somewhere publicly visible. That way their trade counterparties will know that in advance.
It might also me a good idea to have a feedback button that users can click or fill after a trade, to privately “flag” a Bisq account as an Exchange account. If enough Bisq users “flag” an account as an Exchange account, then that information becomes visible to all other users (this might need additional consideration to not be abused).

I think Bisq developers should consider the above information and act as they think is appropriate. I expect that this forum and the information in it is monitored by the dev team. If it’s not, feel free to draw their attention to it with any means you see fit.

Edit: After posting I realized it’s an older thread >.< I don’t know if anything has changed since.

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I think the consensus reached from support discussions was that if your trade party is an exchange you can cancel the trade with no penalty.

You would then be able to block the users onion address so you can not see their offers and they cannot see yours.

Hopefully this solves the concerns you raised?

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