Telegram OTC Desk 44
Telegram OTC Desk 44 · Unlicensed peer-to-peer broker · otc-44 · synthetic attribution
Telegram OTC Desk 44 scores 6.9 of 10 (high risk) as a counterparty, driven mainly by registration and licensing (50.4% of the score). It is unlicensed in Russia, and applies none identity checks. It does not transmit originator information, so a Travel Rule request against a transfer to it cannot be satisfied. Operational footprint covers North Korea, Russia, British Virgin Islands.
Due-diligence pillars
Four pillars are scored 0-10 and combined with fixed weights (licensing 35%, jurisdiction 25%, kyc_aml 30%, operational 10%). The result is on the same 0-10 scale as a wallet score so the two can be compared, but it measures the counterparty's controls, not its transaction history.
- No licence or registration identified in any supervisory regime. (+9.0)
- Operates in scope of MiCA without an authorisation under it. (+1.0)
- Incorporated in Russia, which carries a jurisdiction risk of 7 of 10 in this model. (+7.0)
- Operates from North Korea, a higher-risk jurisdiction than the one it is incorporated in. Where a service actually operates matters as much as where it is registered. (+1.2)
- No transaction monitoring programme was identified. (+5.0)
- Originator and beneficiary information is not transmitted with transfers, so a Travel Rule request cannot be satisfied. (+3.0)
- Customers and counterparties are not screened against sanctions lists. (+2.0)
- Source of funds is not evidenced for large deposits. (+1.0)
- A non-custodial protocol has no customers to identify, so customer-facing controls are not applicable. The residual risk is that it can be used without any identity check at all. (+3.0)
- Holds no customer funds; there is no operator to serve an order on. (0.0)
- With no operator, neither identity information nor a freeze is obtainable from this counterparty. (+2.0)
- Only 1 address(es) are attributed to this entity, so its on-chain behaviour is barely observable and exposure to it may be under-counted. (+1.0)
Registration
| Status | unlicensed |
|---|---|
| Regulator | no identified regulator |
| Evidence | none |
| Reference | none |
| MiCA | not authorised |
Jurisdiction
| Incorporated in | Russia (RU) |
|---|---|
| Operational hubs | KP, RU, VG |
| FATF grey list | no |
| Offshore secrecy | no |
KYC and AML
| KYC rigour | none |
|---|---|
| Withdrawal KYC threshold | none |
| Transaction monitoring | absent |
| Travel Rule | absent |
| Sanctions screening | no |
| Source-of-funds checks | no |
Operational integrity
| Custody model | non custodial |
|---|---|
| Founded | 2022 |
| Chains | ETH |
| Clustered addresses | 1 |
The regulatory file is seeded, not sourced from a register. Licence references and dates are fabricated for demonstration and must never be relied on for a real onboarding decision.