Stopping the $12.5 Billion Fraud Crisis — At Every Layer

Bitcoin ATMs let people convert cash to crypto directly — no exchange accounts, no custodial middlemen, bearer instrument to bearer instrument. That simplicity is worth protecting.

Scammers exploit irreversible transactions — we get why regulators pay attention. But 52.5 billion robocalls and a fraud call center for under $100 show the real crisis starts upstream. Here's how we stop it at every level.

The Crisis in Numbers

Fraud losses are accelerating. The data reveals where the failure actually lies.

$12.5B

Total Fraud Losses (2024)

+25% YoY

FTC 2024 Consumer Sentinel Report

$4.9B

Elder Fraud Losses (60+)

+43% surge

FBI IC3 Elder Fraud Report 2024

52.5B

Robocalls in 2025

Highest since 2019

YouMail Robocall Index

$2,210

Median Loss per Phone Scam

Highest of any contact method

FTC Consumer Sentinel Report

Watch

Blaming Bitcoin ATMs. Every Scam Starts With a Phone Call.

Anatomy of a Scam: Follow the Chain

We strictly regulate the EXIT door but leave the FRONT DOOR wide open.

Step 1

Origination

Scammer purchases VoIP service for ~$100, easily bypassing weak identity checks. Fake name, hotel address, prepaid card — all accepted without meaningful scrutiny.

Ineffective KYC
Step 2

Transmission

Call enters US telecom network. STIR/SHAKEN attestation fails — 48% of illegal calls still carry A-Level trust ratings.

STIR/SHAKEN Failing
Step 3

The Hook

Victim receives spoofed call appearing to be from IRS, Social Security, or law enforcement. "You owe $5,000 or face arrest."

No Content Inspection
Step 4

Bank Withdrawal

Victim withdraws cash from their bank. Banks monitor but rarely intervene — they are facilitators, not guardians.

Monitors, Not Guardians
Step 5

Payment Exit

Cash is inserted at a BTM, wired, or converted to gift cards. This is the ONLY step facing proposed bans.

Heavily Regulated

Banning Step 5 doesn't stop Step 1.

Criminals simply shift to gift cards, gold, or mail-in cash. Until the origination point is addressed, fraud will continue through every available payment channel.

The Regulatory Asymmetry

A side-by-side comparison of how we regulate the tools that enable fraud versus the tools that are blamed for it.

The Front Door: VoIP Providers

How scammers reach their victims

  • No AML program required; KYC is superficial and easily bypassed
  • No SAR filing obligations
  • No state licensing needed
  • No FinCEN registration
  • No surety bond requirements
  • ~$100 setup cost, minimal effective screening
  • $0 annual compliance cost

The Exit Door: Bitcoin ATMs

Where regulation is concentrated

  • Full AML/KYC program mandatory
  • SAR filing required by law
  • State-licensed in 18+ states (and growing), on top of federal BSA requirements
  • FinCEN registered as MSB
  • Surety bonds in most states
  • Photo ID + selfie verification
  • $500K–$2M annual compliance cost
Requirement VoIP Providers Bitcoin ATMs
AML Program Not required Mandatory (BSA)
Suspicious Activity Reports Not required Required by law
State Licenses None 18+ state MTLs (expanding)
FinCEN Registration Not required Registered MSB
Surety Bonds None $10K–$1M per state
Violation Consequence Rarely enforced Criminal penalties
Annual Compliance Cost ~$0 $500K–$2M+

BTM operators spend 5,000x more on compliance than VoIP providers — yet VoIP is where every scam begins.

Follow the Money

When you look at actual fraud losses by payment method, Bitcoin ATMs are a fraction of the total.

Fraud Losses by Payment Method

Check Fraud (Global) $26.6B
Bank Transfers $2.09B
Wire Transfers $287M
Bitcoin ATMs $246.7M

Only 1.5% of total internet crime losses

98.8%

Legitimate

of all crypto ATM transactions are lawful*

* See full report for detailed sources. See also: TRM Labs, Chainalysis

FCC Enforcement Failure

$208M

Fines Levied

$6,790

Actually Collected

0.003%

Collection Rate

STIR/SHAKEN Investment

hundreds of millions of dollars invested in caller ID authentication — 48% of illegal calls still carry A-Level trust ratings.

Where Fraud Can Be Stopped

Effective fraud prevention requires intervention at every layer — not just the last one. Here's what a systemic solution looks like.

Telecom Layer

Caller Authentication: Enforce STIR/SHAKEN attestation with real penalties for carriers that grant trust ratings to unverified originators.
VoIP KYC Requirements: Extend Bank Secrecy Act identity verification to VoIP providers — the $0-compliance loophole that lets scammers operate for $100.
Robocall Blocking: Mandate carrier-level blocking of calls from non-compliant originators, not just optional consumer tools.

Banking Layer

Withdrawal Alerts: Real-time alerts to account holders and family members when large cash withdrawals occur, especially for seniors.
Confirmation of Payee: Adopt the UK model that reduced authorized push payment fraud by nearly 60% — verify the recipient before funds leave.

ATM Layer

Identity Verification: Government-issued photo ID with liveness detection for every transaction. No anonymous usage.
Behavioral Monitoring: AI-powered detection of duress signals, phone-guided behavior, and unusual transaction patterns in real time.
Proactive Outreach: Live calls to customers aged 60+ after flagged transactions — Byte Federal's program prevents 84% of potential elder fraud.

Blockchain Layer

Wallet Screening: Real-time screening of destination wallets against known scam addresses and sanctioned entities before transactions complete.
On-Chain Analytics: Pattern detection across the blockchain to identify and flag wallets associated with fraud networks.

Fraud is a pipeline problem — it requires a pipeline solution.

No single layer can stop fraud alone. By strengthening every intervention point, we protect consumers without removing the financial tools they depend on.

Byte Federal's Five-Layer Defense

While regulators debate upstream solutions, we're protecting customers right now.

84%

Elder Fraud Prevention Rate

Through proactive outreach calls to customers aged 60+, Byte Federal prevents 84% of potential elder fraud cases from completing.*

KYC & Identity Verification

Government-issued photo ID verification with liveness detection for every transaction. No anonymous usage permitted.

Trained BSA Officer Monitoring

Dedicated BSA-trained compliance officers and support staff review transactions for signs of duress, coaching, or phone-guided behavior. Rule-based transaction monitoring flags unusual patterns for human review.

Mandatory Kiosk Warnings

Age-sensitive, on-screen scam education displayed before every transaction. Customers over 60 see enhanced warnings about common government impersonation scams.

Anti-Fraud Terms of Service

Terms explicitly prohibit coerced transactions. Customers must affirmatively confirm they are not being directed by a third party.

Live Outreach Calls to 60+ Customers

Byte Federal proactively calls customers aged 60+ after flagged transactions. This program alone prevents 84% of potential elder fraud cases from completing.

Case Studies: When the Front Door Fails

Real incidents that demonstrate how unregulated telecom access enables large-scale fraud.

The "MarioCop" Incident

2022

A scammer registered a VoIP line using a fake name, a hotel address, and anonymous Bitcoin. The application was approved without question.

  • Registered with alias 'MarioCop' — no real identity check
  • Used a hotel as a business address
  • Paid with anonymous cryptocurrency
  • Originated hundreds of government imposter scam calls
  • VoIP provider faced no consequences for enabling the fraud

“In banking, this onboarding would be a crime. In telecom, it was standard practice.”

The Biden Deepfake Robocall

January 2024

Lingo Telecom gave A-Level STIR/SHAKEN attestation to an AI-generated deepfake robocall impersonating President Biden, used for voter suppression in New Hampshire.

  • AI-generated voice clone of President Biden
  • Targeted New Hampshire primary voters
  • Received A-Level attestation — the highest trust rating
  • Lingo Telecom knew the originating customer
  • Demonstrated that STIR/SHAKEN verifies identity, not intent

“They knew the customer — but didn't inspect the content. The highest trust rating in American telecom was awarded to a machine-generated lie.”

Who Gets Hurt When You Ban the Bridge

Banning Bitcoin ATMs punishes the most vulnerable Americans while doing nothing to stop the source of fraud.

24.6M

24.6 Million Unbanked Americans

Crypto ATMs serve as critical financial infrastructure for communities with limited banking access. Banning them removes a lifeline.

  • Native American households: 12.2% unbanked
  • Black households: 10.6% unbanked
  • Hispanic households: 9.5% unbanked
  • White households: 1.9% unbanked

~60%

UK's Confirmation of Payee

The UK's Confirmation of Payee system reduced authorized push payment fraud by nearly 60%. The United States has not adopted any equivalent measure.

2026

Supreme Court Threat to FCC Authority

A pending Supreme Court case (April 2026) may eliminate the FCC's ability to levy fines against telecom violators entirely, removing the last enforcement mechanism.

Enforce existing laws to stop the signal, rather than banning the bridge that serves 24 million Americans.

Resources & Reports

Download the full research behind these findings.

MarioCop and the Failed War on Robocalls

Audio briefing

The Architecture of Exploitation

Comprehensive briefing on how unregulated telecom infrastructure enables the fraud ecosystem.

Download PDF

Securing the Bridge

Policy framework for protecting crypto ATM access while stopping fraud at the source.

Download PDF

Closing the Telecom Regulatory Gap

Analysis of the regulatory asymmetry between telecom and financial services compliance.

Download PDF

Frequently Asked Questions

The vast majority of fraud attributed to crypto ATMs originates from unregulated telephone calls. Scammers use VoIP services — available for as little as $100 with only ineffective identity screening that is easily bypassed — to impersonate government agencies, law enforcement, and financial institutions. The phone call is the weapon; the ATM is merely one of many payment methods the scammer directs the victim to use. Bank wires, gift cards, and cash-by-mail are equally common endpoints.
Byte Federal employs a five-layer fraud prevention system: (1) Full KYC identity verification with liveness detection, (2) Trained BSA officers and compliance staff who monitor for signs of duress or coaching, (3) Mandatory on-screen scam warnings tailored by age, (4) Anti-fraud Terms of Service requiring customers to confirm they are not being directed by a third party, and (5) Proactive outreach calls to customers aged 60+, which alone prevent 84% of potential elder fraud cases.*
A scammer calls the victim using a spoofed caller ID that appears to be from the IRS, Social Security Administration, or local police. The victim is told they owe money, face arrest, or have had their identity stolen. Under duress, they are instructed to withdraw cash from their bank and deposit it at a Bitcoin ATM, wire it, or purchase gift cards. The scam originates and succeeds because of the phone call — the ATM is simply the last step in a chain that starts with unregulated telecom access.
Banning Bitcoin ATMs would punish 24.6 million unbanked Americans — disproportionately Native American, Black, and Hispanic households — who rely on these machines for financial access. It would also have minimal impact on fraud: criminals would simply redirect victims to wire transfers, gift cards, or cash-by-mail, which collectively account for far more fraud losses. The data shows that only 1.5% of total internet crime losses involve crypto ATMs. Banning them addresses a symptom while leaving the root cause — unregulated telecom — completely untouched.
Regulators should focus on the origination point of fraud: the telecom infrastructure. Specific recommendations include: (1) Extend Bank Secrecy Act KYC/AML requirements to VoIP providers, (2) Mandate real-time content attestation beyond STIR/SHAKEN caller ID verification, (3) Fund the FCC to actually collect the $208M in levied fines (current collection rate: 0.003%), (4) Adopt the UK's Confirmation of Payee system to catch authorized push payment fraud, and (5) Hold telecom carriers liable when they knowingly transmit fraudulent traffic.
Byte Federal's 84% elder fraud prevention rate* through proactive outreach calls is among the highest in the industry. While many operators rely solely on passive warnings, Byte Federal actively contacts customers aged 60+ when transactions are flagged, intervening before the fraud completes. Combined with trained BSA officer monitoring, mandatory scam education, and strict KYC, Byte Federal's multi-layered approach goes well beyond regulatory minimums. The industry-wide legitimate transaction rate for crypto ATMs is 98.8%*.
98.8% of all crypto ATM transactions are legitimate. The narrative that Bitcoin ATMs are primarily tools for fraud is contradicted by the data. Crypto ATMs serve millions of Americans for lawful purposes: purchasing cryptocurrency, sending remittances, accessing financial services without a traditional bank account, and converting between cash and digital assets. The 1.2% fraud rate is comparable to or lower than fraud rates for credit cards, wire transfers, and other mainstream payment methods.
VoIP providers fall under FCC jurisdiction, not FinCEN, and are classified as telecommunications carriers rather than financial services. This means they have zero obligations under the Bank Secrecy Act: no anti-money laundering programs, no suspicious activity reporting, and no state licensing requirements. While some VoIP providers perform basic identity checks, these are ineffective and trivially bypassed. While VoIP providers face far lighter regulatory burdens than crypto ATM operators — no FinCEN registration, no AML program, no state money transmitter licensing — they do face revenue-based federal obligations including USF contributions and CALEA compliance. The contrast in compliance burden is stark, but the core problem remains: a scammer can stand up a fraud operation with minimal friction, using a fake name and prepaid card, with fines that go largely uncollected. In banking, that onboarding would be a federal crime. This regulatory gap is the single largest enabler of consumer fraud in the United States.

Stop the Signal. Stop the Theft.

The data is clear. The solution is upstream. Let's work together to close the telecom regulatory gap and protect consumers at the source.

For Regulators

Data-driven policy analysis and enforcement recommendations

For Press

Source documents, statistics, and expert commentary

For Customers

How to identify and avoid phone-based scams