Table of contents
- The Jiřikovský Bitcoin case and the fundamental AML mistake
- The document may be fine. The origin is not.
- What actually happened in this case (from an AML perspective)
- The most common AML mistake: transfer of authority
- How a properly set up AML system should react
- Why this matters even for "ordinary" companies
The Jiřikovský Bitcoin case and the fundamental AML mistake
At first glance, it sounds logical. A person donates some bitcoins to the state. The state accepts them. So the remaining bitcoins must be "fine". Otherwise, the state wouldn't have taken them.
This exact argument appeared in the Tomáš Jiřikovský case. And this is where the fundamental AML problem lies.
It's not about politics. It's not about emotions. It's about a fundamental misunderstanding of what AML actually evaluates.
The document may be fine. The origin is not.
AML never evaluates how nice a document looks. AML evaluates where the money actually comes from.
- A donation agreement may be valid
- A donation agreement may be signed by the state
- A donation agreement may be legally flawless
- but it doesn't change the history of the money
If bitcoins originated as proceeds of crime, they remain so even after part of them passes through the state. The state is not a laundromat. And a donation is not a certificate of cleanliness.
What actually happened in this case (from an AML perspective)
Simply put:
The police evaluate this as an attempt to launder proceeds of crime.
- A person convicted of operating a darknet drug marketplace gains access to bitcoins.
- They donate part of these bitcoins to the state.
- An impression is created: "if the state accepted the donation, the rest is legitimate".
- This impression is used in an attempt to convert the remaining bitcoins into money.
From an AML perspective, point 3 is critical. Not because it's "immoral". But because it's logically and methodically wrong.
The most common AML mistake: transfer of authority
This case shows a very dangerous pattern that we encounter in AML increasingly often:
"If it passed through the state / court / notary, it must be clean."
- That's a mistake.
- AML doesn't work on the principle of authority.
- It works on the principle of source of funds / source of wealth.
- Authority doesn't rewrite history, erase criminal origin, or guarantee cleanliness.
- On the contrary. If someone actively invokes authority as proof of cleanliness, that's a red flag in itself.
How a properly set up AML system should react
How a properly set up AML system should react
A proper AML approach would do the following:
- It wouldn't evaluate "who took what", but how the money originated.
- It would evaluate criminal history and darknet context as deterministically high risk.
- It would trigger enhanced due diligence (EDD), not simplified onboarding.
- It would treat documents at most as supplementary information, not as proof of origin.
- It would stop and escalate the transaction.
This isn't strictness. This is basic risk-based AML logic.
Why this matters even for "ordinary" companies
This case isn't exotic. It's just extremely visible.
The same principle appears on a smaller scale every day: "I have a contract, so it's fine." "I have confirmation, so we don't need to deal with it." "If it passed elsewhere, we're covered." You're not. An obliged entity is responsible for its own AML decisions. Not for someone else signing something.
AML isn't a formality. It's a defense system. The Jiřikovský case isn't interesting because it's media-worthy. It's interesting because it shows exactly the moment when formal approach fails and only real AML thinking stands. AML PROOF is built on exactly this difference: not on collecting papers, but on understanding risk, not on impressions, but on origin, context, and logic. Because dirty money today doesn't try to be invisible. It tries to be paper-clean.