Ripple Labs: Attachment B, Remedial Framework
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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.
ATTACHMENT B: REMEDIAL FRAMEWORK
1. Monetary Penalties:
Ripple Labs Inc. and XRP II, LLC (formerly known as XRP Fund II, LLC) agree to
forfeit $450,000.00 to the Office of the United States Attorney for the Northern
District of California (“U.S. Attorney’s Office”). Ripple Labs and XRP II further
agree to pay a civil money penalty to FinCEN in the amount of $700,000.00, within
30 days of the date of this agreement. Payment of the forfeiture to the U.S.
Attorney’s Office shall be deemed creditable toward FinCEN’s civil money penalty.
2. Migration of Ripple Trade/Ripple Wallet to Registered MSB:
Within 30 days of the date of this agreement, Ripple Labs and XRP II will move its
service known as Ripple Trade (formerly known as Ripple Wallet, which allows end
users to interact with the Ripple protocol to view and manage their XRP and fiat
currency balances), and any such functional equivalent, to a money services business
that is registered with FinCEN (the “Ripple Trade MSB”).
a) Any sale or transmission of XRP by Ripple Labs or any of its subsidiaries
shall be conducted only through an entity registered with FinCEN;
b) Users of Ripple Trade (which will include all users registering after the date
of this agreement and any existing users who register at the request of Ripple
Labs) will be required to submit customer identification information, as
required under the rules governing money services businesses, to the Ripple
Trade MSB;
c) Ripple Labs, via the Ripple Trade MSB, will offer incentives, including but
not limited to XRP giveaways, for existing Ripple Trade users to transfer a
wallet with customer identification information or account (that is, a wallet or
account with customer identification information); and
d) After 180 days of the date of this agreement, Ripple Labs will (1) prevent any
existing Ripple Trade user who has not transferred to a wallet or account with
customer identification information from accessing the Ripple protocol
through the Ripple Trade client, and (2) not otherwise provide any support of
any kind to such a user in accessing the Ripple protocol.
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3. Maintenance of Registration:
Ripple Labs and XRP II will maintain, or continue to maintain, XRP II’s and the
Ripple Trade MSB’s registrations with FinCEN, including such re-registrations
required by 31 U.S.C. § 5330.
4. Effective AML Program:
XRP II and the Ripple Trade MSB will implement and maintain, or will continue to
maintain, an effective anti-money laundering (“AML”) program, risk assessment, and
other compliance measures as required by applicable law, including the Bank Secrecy
Act and its implementing regulations.
5. AML Compliance Officer:
XRP II and the Ripple Trade MSB will maintain, or will continue to maintain, an
anti-money laundering compliance officer to ensure day-to-day compliance with their
obligations under the Bank Secrecy Act and its implementing regulations.
6. Training Program:
a) Within 45 days after the date of this agreement, XRP II and the Ripple Trade
MSB will create an AML training program for Bank Secrecy Act/AML
compliance and will provide a copy of the training program to the U.S.
Attorney’s Office and FinCEN;
b) Within 45 days of the date of this agreement, XRP Fund II and the Ripple
Trade MSB will provide training to each of their employees and provide to the
U.S. Attorney’s Office and FinCEN written evidence of such training,
including a certification of such training, the name of each employee who
attended such training, and the dates of such training.
7. External audit:
Within 60 days, XRP II and the Ripple Trade MSB will secure and retain an
independent, external, and qualified party or entity (the “Third-Party Reviewer”), not
subject to any conflict of interest, and subject to FinCEN’s and the U.S. Attorney’s
Office’s determination of non-objection, to examine their Bank Secrecy Act
compliance programs and evaluate whether the programs are reasonably designed to
ensure and monitor compliance with the requirements of the Bank Secrecy Act and
the FinCEN rules applicable to money services businesses. Three reviews will occur:
the first will commence within one year of this agreement; the second will occur in
2018; and the third will occur in 2020. Each review will cover the previous two
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years, with no less than six months’ worth of transactional analysis of those
transactions in which XRP II and the Ripple Trade MSB was a party or served as an
exchanger. The Third-Party Reviewer will prepare a written report for each
company’s audit committee and the board of directors, setting forth its findings, and
will transmit the report and all draft reports to the U.S. Attorney’s Office and FinCEN
simultaneously with any transmission to XRP II, the Ripple Trade MSB, or their
agents. To the extent that the report identifies any material deficiencies in XRP II’s
or the Ripple Trade MSB’s programs and procedures, XRP II and the Ripple Trade
MSB shall address and rectify the deficiencies as soon as is reasonably practicable.
8. Enhancements to Ripple Protocol:
Within 60 days, Ripple Labs, XRP II, and the Ripple Trade MSB will improve, and
upon request provide any information requested by FinCEN or the U.S. Attorney’s
Office as to the use and improvement of, existing analytical tools applicable to the
Ripple protocol, including: (1) reporting regarding any counterparty using the Ripple
protocol; (2) reporting as to the flow of funds within the Ripple protocol; and (3)
reporting regarding the degree of separation.
9. Look-Back for Suspicious Activity:
Within 180 days of the date of this agreement, Ripple Labs and XRP II will conduct a
review of all prior transactions and attempted transactions to which Ripple Labs
and/or XRP II was a party or served as an exchanger, within the last three years
involving or aggregating to at least $2,000.00 in funds or other assets. For any such
transaction for which it is known, suspected, or there is a reason to suspect that the
transaction (a) involves funds involved in illegal activity; (b) is intended or conducted
in order to hide or disguise funds or assets derived from illegal activity, or to disguise
the ownership, nature, source, location, or control of funds or assets derived from
illegal activity; (c) is designed, whether through structuring or other means, to evade
any requirement in the Bank Secrecy Act or its implementing regulations; (d) serves
no business or apparent lawful purpose, where the MSB knows of no reasonable
explanation for the transaction after examining the available facts, including the
background and possible purpose of the transaction; or (e) involves use of the MSB to
facilitate criminal activity, Ripple Labs and/or XRP II will file a Suspicious Activity
Report within 30 days of such determination.
10. Transaction Monitoring:
Ripple Labs will institute AML programmatic transaction monitoring across the
entire Ripple protocol, and will report the results of such monitoring to the U.S.
Attorney’s Office, FinCEN, and any other law enforcement or regulatory agency
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upon request. The monitoring and reporting must include, at a minimum: (a) risk
rating of accounts based on the particular gateway used; (b) dynamic risk tools to
facilitate investigation of suspicious activity, including counterparty reporting, flow
of funds reporting, account flagging of suspicious accounts, and degrees of separation
reporting; and (c) other reports of protocol-wide activity regarding any unlawful
activity.
11. Funds Travel Rule and Funds Transfer Rule:
XRP II and the Ripple Trade MSB will ensure, or continue to ensure, that all
transactions made using XRP II, Ripple Trade, or Ripple Wallet will be, or will
continue to be, in compliance with the Funds Transfer Rule and the Funds Travel
Rule.
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