This Legal Process Guide is designed to assist law enforcement in understanding CoinFlip’s business, its policies and practices with regard to the disclosure of information, and to provide answers to frequently asked questions related to subpoenas and other legal processes. The policies, procedures and kiosk workflow in this guide are subject to change from time to time without notice, and this guide is not meant to be distributed to individuals or organizations that are not law enforcement agencies. Nothing in this guide is intended to create any enforceable rights against CoinFlip, and CoinFlip will make reasonable efforts to advise law enforcement of significant changes in policies or procedures through updates to this guide.
Incorporated in December 2015, and headquartered in Chicago, Illinois, CoinFlip operates Bitcoin ATMs (“BATMs” or “kiosks”) across the United States and other select countries as well as a remote over the-counter cryptocurrency order desk and a Mobile Application. CoinFlip is registered as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN). Further, CoinFlip has obtained Money Transmitters Licenses (“MTL”) in states where it is required for CoinFlip to conduct business. CoinFlip’s policy is to prohibit and actively prevent money laundering activities or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act of 1970 (“BSA”), the United States PATRIOT Act, and their implementing rules and regulations. CoinFlip’s BSA/anti-money laundering (“AML”) policies and internal controls are designed to ensure compliance with all applicable regulations and are reviewed and updated on a regular basis to account for both changes in regulations and changes in CoinFlip’s business model. CoinFlip implements and Know Your Customer (KYC) requirements in adherence to federal and state law. All customers and digital wallet addresses are checked against government watchlists, including the Office of Foreign Assets Control (“OFAC”) list. In addition, pursuant to CoinFlip’s BSA/AML program, CoinFlip files Suspicious Activity Reports (“SAR”) when transactions appear to be potentially suspicious, unusual, or unlawful and Currency Transaction Reports (“CTR”) for all transactions over $10,000.
CoinFlip BATMs are physical machines located in businesses that allow customers to buy or sell select cryptocurrencies with cash. CoinFlip operates over 5,000+ BATMs across 49 states, the District of Columbia, and Puerto Rico as well as Australia, Canada, Italy, New Zealand, Spain, and South Africa. At BATMs, customers can purchase cryptocurrency with physical fiat currency. At select locations, customers are able to sell their cryptocurrency for fiat currency. When buying cryptocurrency at a BATM, they are first shown CoinFlip’s “Safe in Six” screen which includes six questions associated with specific fraud typologies (described further below). In the event a customer answers yes to any question, they are directed to call CoinFlip’s customer service. The customer must then create an account with CoinFlip and provide all relevant KYC information. Next, the customer selects what cryptocurrency they would like to purchase and the amount they wish to purchase. The customer must agree to warnings regarding their transaction (described further below), CoinFlip’s Terms of Service (https://coinflip.tech/terms/terms-of-service), and its Privacy Policy (https://coinflip.tech/terms/privacy-policy). The customer then scans their digital wallet address which is screened and risk rated. The customer next inserts the physical fiat currency into the BATM to make their purchase. Once finished, CoinFlip completes the transaction sends the purchased cryptocurrency to the digital wallet provided by the customer. Customers are subject to daily limits based on information received by CoinFlip. Further, CoinFlip does not custody or control customer funds.
Please refer to this link for further details on how the Bitcoin ATM works: https://coinflip.tech/blog/how-does-a-bitcoin-atm-work
CoinFlip operates a remote over-the-counter virtual currency order desk under the name “CoinFlip Preferred” where customers can buy or sell select cryptocurrency via wire transfers and ACH. The order desk services residents in 49 states, Puerto Rico, the District of Columbia, Australia, and Canada. Similar to the BATMs, CoinFlip customers are required to acknowledge CoinFlip’s Terms of Service (https://coinflip.tech/terms/terms-of-service) and Privacy Policy (https://coinflip.tech/terms/privacy-policy) for order desk services which includes a disclaimer that all transactions are final and that customers are required to send cryptocurrency to only digital wallets they fully own and control. CoinFlip Preferred only sends fiat and cryptocurrency to the customer and does not permit customers to send fiat or cryptocurrency to a third party.
When buying cryptocurrency at CoinFlip Preferred, a customer must initially register via its website (https://coinflip.tech/otc). The customer must initially provide their phone number and agree to CoinFlip Preferred’s Terms of Service and Privacy Policy. Next, the customer must provide all relevant KYC information in order to proceed with a purchase. After passing compliance checks, the customer must submit a purchase order including the type of cryptocurrency for purchase, the amount for purchase, and the customer’s digital wallet address. After submission, the customer is assigned a sales manager from CoinFlip Preferred who is available to assist with the purchase process. CoinFlip sends a quote via text message to the customer including the type of cryptocurrency, the amount of purchase, the digital wallet address, and all fees charged. The customer must agree to the quote in order to proceed. Once the customer agrees, the customer transfers the purchase amount via wire or ACH to CoinFlip’s bank account. Once received, CoinFlip sends the purchased cryptocurrency from its digital wallet address to the customer’s specified digital wallet address.
CoinFlip operates a Mobile Application that allows users to create a non-custodial digital wallet address to store cryptocurrency. CoinFlip has no control over the cryptocurrency in customers’ digital wallet addresses. Customers can send the cryptocurrency in the digital wallet to other digital wallets. Customer’s digital wallet created in the CoinFlip Mobile App may receive cryptocurrency from other digital wallets. Customers can also locate nearby CoinFlip BATMs with the CoinFlip Mobile App.
The CoinFlip Mobile App and website use Onramper to connect customers to third parties to buy and sell virtual currency via debit, ACH, or Apple Pay. When a customer makes a purchase or sale of cryptocurrency, they are directly transacting with the third-party. As a result, CoinFlip does not have purchase or KYC information for those individuals and the third-party where the transaction was completed must be contacted for further information.
CoinFlip will occasionally receive subpoenas, search warrants or other official information requests from law enforcement. Upon receiving the subpoena, CoinFlip will review the validity of the request and verify the sending authority. CoinFlip will respond within 30 days of receipt, unless a shorter time frame is requested based on the time sensitive nature of a significant pending criminal investigation.
CoinFlip accepts service of subpoenas, search warrants and other information requests for criminal matters through [email protected].
For CoinFlip to locate records of a CoinFlip customer or transaction(s), subpoenas should provide identifying information, including but not limited to:
● Customer full name
● Customer phone number
● Customer date of birth
● Customer email address
● Customer physical address
● Customer SSN
● Date(s) of transactions
● Location of transactions (location of Bitcoin ATM)
● Transaction ID
● Hashes
● Full digital wallet address
There is a higher probability of CoinFlip being able to locate responsive documents to a subpoena if more identifying information is provided. Accordingly, in drafting a subpoena or search warrant for such information, law enforcement should be as specific as possible. Narrowly tailored requests yield significantly faster results and create fewer opportunities for misinterpretation.
Subpoena Language Example 1:
Please provide the customer information and transaction history for any accounts associated with the following identifiers for the timeframe between January 1, 2020, to August 1, 2022:
Name: Jane Doe
DOB: 1/1/2001
Phone Number: (XXX) XXX- XXXX
Email Address: [email protected]
Documents may include:
● Account/Customer ID
● Customer Identifying information, to include names, address, email address, mobile numbers, identity and location verification documents
● Any KYC information
● Transaction history
● Any communications between CoinFlip and customer
Subpoena Language Example 2:
I am requesting customer information, including name, phone number, email address, transaction history, and any identifying information associated with the following transaction: Transaction ID ABCDE in the amount of $900 that was sent to wallet address a1b2c3d4e5f6g7h8i9j1k2l3 on March 1, 2022, 9:45:52 PM at the terminal located in 123 Apple Rd. Chicago, IL 60007.
Please provide the requested information related to the identified customers above for the period of January 1, 2022, to August 1, 2022.
Depending on whether CoinFlip can locate records based on the identifying information provided by law enforcement in the subpoena, CoinFlip’s response may contain different types of information based on various factors, including the types and amounts of transactions made by the customer and the types of KYC information that is collected. Based on these factors, CoinFlip’s response to the subpoena may include:
KYC information collected by CoinFlip regarding the customer (such as name, phone number, address, ID, IP address, financial information, source of funds and reason for transactions, etc.)
Customer’s transaction history
Including dates, amounts, receiving wallet addresses, type of cryptocurrency purchased/sold, CoinFlip’s transaction ID
ATM Terminal (kiosk) location information for where customer transacted
Transaction hash number for transactions (please refer to the Commonly Asked Questions section below for explanation on what is a transaction hash number)
Customer correspondence including emails, texts, or customer support phone calls
Law enforcement may send a request for supporting documentation for filed SARs to [email protected]. In order for CoinFlip to process this request, we require the full BSA SAR ID, the internal control number listed on the SAR, as well as the subject’s name and any additional identifying information that may be helpful.
Law enforcement may send preservation requests to [email protected]. Please provide the relevant information required for CoinFlip to comply, including the reason for the request and the necessary identifying information for CoinFlip to comply.
At CoinFlip, we take consumer protection seriously and have implemented safeguards to help protect consumers, work alongside law enforcement, and refund transaction fees to scam victims in instances of fraud.
Please refer to this link for further details on the transaction fee refund process: https://coinflip.tech/terms/transaction-fee-refund-process.
What is Cryptocurrency?
Cryptocurrency is a form of virtual currency which is created and held digitally, such as Bitcoin or Ethereum. Cryptocurrency allows for peer-to-peer transactions that are verified and maintained by a decentralized system utilizing cryptography, without the need of a third party or financial institution. Most cryptocurrencies utilize a technology called the blockchain, a publicly available digital ledger where cryptocurrency transactions are recorded and tracked. Similar to traditional fiat currencies like the US Dollar or Euro, you can exchange cryptocurrency for goods and services, although not every store may accept cryptocurrency as a form of payment at this time. For more general information regarding cryptocurrency, we recommend you visit our “Learn” page at: https://coinflip.tech/learn.
Once a customer completes a transaction with CoinFlip, can the transaction be reversed? Can a customer be refunded if he/she was scammed?
All transactions made by the customer are final and irreversible, as provided in CoinFlip’s Terms of Service. There are limited circumstances when CoinFlip may hold transactions or refunds may be available pursuant to state law. In the event you believe that a transaction may be refundable, please contact CoinFlip as soon as possible. Please see CoinFlip’s disclosures in order to determine if a refund may be possible: https://coinflip.tech/terms/licenses. CoinFlip is unable to reverse any transactions after they have been completed due to the nature of blockchain. Transactions happen nearly instantly and are irreversible once completed.
What types of warnings are provided to customers by CoinFlip?
Customers are explicitly warned that all transactions made at the ATM or the Order Desk are final and irreversible through CoinFlip’s Terms of Service. Furthermore, in efforts to prevent fraud, customers at the kiosks are provided scam warnings and must agree that they are only sending cryptocurrency to a digital wallet that they fully own and control. Every customer is presented with CoinFlip’s Safe in Six on the kiosk prior to every transaction:
Additionally, each customer is presented with a prominent scam warning prior to every transaction and is required to agree they are sending funds to a digital wallet address they own and control:
Lastly, customers are presented with the Terms of Service on the same screen that include the following prominent scam disclaimer:
STOP AND READ THIS MESSAGE IMMEDIATELY!! Have you been sent to this ATM to make a payment for ANYTHING, such as SSN fraud, taxes, utility bills, tickets, cars, equipment, money transfers, ransom, bail, eBay, Airbnb, or anything odd?
STOP! You are being scammed, hang up and call us at 877-7572646. ALL TRANSACTIONS ARE FINAL AND IRREVERSIBLE!! FRAUDULENT TRANSACTIONS MAY RESULT IN THE LOSS OF YOUR MONEY OR CRYPTOCURRENCY OR BOTH, WITHOUT RECOURSE. WE HAVE ABSOLUTELY NO RESPONSIBILITY OR LIABILITY FOR ANY UNAUTHORIZED, MISTAKEN, OR ACCIDENTAL TRANSACTIONS MADE BY YOU OR ANY OTHER PERSON USING YOUR ACCOUNT OR WALLET. Never send bitcoin or any cryptocurrency to someone you don't know, or haven't met in person. By accepting these Terms of Service, you acknowledge that you fully own and control the cryptocurrency wallet and funds you plan to use at this Service.
What is a digital wallet and how do they work? Does CoinFlip host digital wallets for customers?
A digital wallet is generally a financial transaction application that allows an individual to receive, store, and send cryptocurrency. CoinFlip does provide a non-custodial digital wallet through its Mobile Application; however, CoinFlip does not host digital wallets at this time and does not have custody over any customer funds. Customers are required to use digital wallet addresses they own and fully control through a third-party provider. Some popular third-party digital wallet providers are Exodus, Coinbase, Gemini and Kraken. When customers make transactions with CoinFlip, they provide the digital wallet address where they would like their cryptocurrency sent to. Customers must acknowledge to only use and send cryptocurrency to digital wallets they fully own and control to prevent fraud. Once CoinFlip sends the purchased cryptocurrency to the digital wallet address provided by the customer, CoinFlip no longer has control over that cryptocurrency.
Digital wallets are often anonymous by nature and do not have any identifying information associated with it. As such, CoinFlip does not have any identifying information relating to the third-party digital wallets that are used by our customers. CoinFlip only has access to and maintains identifying information of the actual customers making the transaction(s) with CoinFlip.
What is the transaction hash number?
A blockchain is a digitally distributed, decentralized, public ledger that records peer-to-peer cryptocurrency transactions. All cryptocurrency transactions recorded on the blockchain are given a unique transaction hash number. The transaction hash, in simple terms, can be thought of as a receipt number to locate a transaction on the blockchain.
Any questions relating to a subpoena, search warrant, or any similar legal process may be directed to the legal team by submitting them to [email protected].
Last updated: April 9th, 2026