An exchange account is, in administrative terms, a compliance record. The account opening requires identity documents, an address, a tax identifier, and the source of funds for any substantial deposit. Each subsequent interaction adds to the record: the deposits, the withdrawals, the trades, the transfers to external wallets, the patterns of activity that the exchange's monitoring systems analyse. The record continues for as long as the relationship exists, and in most jurisdictions, for several years after it ends.

The record is not, primarily, a record of holdings. The exchange does not need to hold the cryptocurrency itself for the record to be substantial. It needs only the verified identity and the transactional history that connects that identity to the wallets it has used. From this, a complete account of the holder's cryptocurrency activity, including activity that has moved well beyond the exchange, can be reconstructed by anyone with the right access.

Who has the right access varies. The exchange itself, plainly. The exchange's banking partners, in their fraud and anti-money-laundering functions. The regulator of the exchange's home country. The tax authority of the holder's country of residence, increasingly often through automatic exchange of information frameworks. The exchange's compliance team and the third parties they engage for screening services. The exchange in another country if the holder opens an account there and the two exchanges share information.

The cumulative effect is that a substantial holder is, through their exchange relationships, well documented to several parties simultaneously. The documentation is, in its individual elements, routine. Combined, it produces a comprehensive picture of an asset class that many holders still describe as private.

the desk works with substantial holders of cryptocurrency on the records that surround their holdings rather than the holdings themselves. The desk does not access exchange accounts and does not hold credentials. It maps the public on-chain record against the holder's identifiers, traces the surrounding documentation, and addresses, through the proper administrative channels, what can be addressed.

A fuller account of the desk's approach in this area is in the desk's work on protecting cryptocurrency and digital asset holdings.