Compliance Errors of Intermediaries and Secondary Liability in the Crypto Industry: Legal Consequences of Improper Due Diligence and User Rights Protection
This report analyzes the growing enforcement practice of holding crypto platforms liable for compliance system defects. The research focuses on the “secondary liability” of intermediaries, where errors in AML and KYC algorithms lead to unjustified asset freezes for bona fide users. The author details the legal conflicts arising from delegating control functions to private companies and analyzes the consequences of using inaccurate analytical data for discriminatory decision-making. Special emphasis is placed on mechanisms for appealing intermediary actions and the need to establish liability standards for damages incurred by users as a result of automated compliance errors and institutional negligence.
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