Illustration by Fernando Capeto for Forbes; Photos by Malerapaso/Getty Images; Pete Starman/Getty Images

Though less than one percent of cryptocurrency transactions last year were considered illicit, according to blockchain data firm Chainalysis, that was still a record $20 billion, most of which is marked as dirty by a cottage industry of blockchain-data startups managing independent and unofficial blacklists. Crypto sitting on a blacklist is difficult to use and many crypto exchanges like Coinbase and Kraken refuse to accept it.

Instead of selling those assets at an auction the way the U.S. Justice Department has done for 185,000 bitcoins it has seized over the last nine years, attorney Ringwald partnered with Frankfurt-based Bankhaus Scheich, which has a fledgling side business in cleaning the blacklisted cryptocurrencies. So far it has cleaned and sold some €150 million worth of dirty digital assets for the state of Hesse.

Yesterday, in partnership with the FBI and German Federal police, the state of Hesse seized another €46 million worth of bitcoin and other cryptocurrency from two servers they believe are responsible for laundering $700 million for North Korea and an undisclosed amount to help the Russian military buy malware.

Over the past month, two other states have signed deals similar to Hesse’s, according to the bank’s managing director of digital assets, Nils von Schoenaich-Carolath, 34, and other German states are currently exploring similar services, he says. As U.S. banks with crypto exposure are facing an existential threat in the wake of the ripple effects surrounding the bankruptcy of crypto exchange giant FTX, Bankhaus Scheich’s CEO and co-founder Wolfgang Beck, sees his firm’s work as a model for how clear regulations and innovative banking practices can upgrade financial infrastructure while protecting users.

“This new digital-asset business is for so many people kind of a strange thing, which they do not understand,” says Beck, 64, who is the bank’s sole shareholder. “So I’m trying to give them the feeling that an old house for trading securities is now doing the same thing with a digital asset. We want to take all of these people, all these institutions, to find a solution for their clients in the new markets. So they have to go over the bridge, plug in, and onboard on our platform for digital assets.”

Bankhaus Scheich was founded in 1985 as Scheich & Partner Börsenmaklermarket, an OTC trader for fixed-income products like bonds. Over the past eight years, the firm has expanded in a number of ways, laying the foundation for its forays into crypto. In 2015, it was licensed as a securities trading bank by Germany’s financial services regulator and now transacts hundreds of millions of euros a day worth of traditional OTC volume and fixed-income assets listed on the Frankfurt Stock Exchange, including securities of Bayer, Lufthansa and Volkswagen.

In 2018, Bankhaus Scheich expanded to capital markets. Recognizing the traditional need for companies to pre-fund million-dollar investments through regulated brokers, the firm started building a suite of institutional crypto services, called Tradias, that lets financial-services firms conduct OTC trades, market making and create securities tokens on the Ethereum and Polygon blockchains. Periodically, the crypto trades are netted out internally, and the bank buys and sells digital assets on exchanges, including Kraken, Binance and formerly on now-defunct FTX.

At around the same time Bankhaus Scheich entered the capital markets, Ringwald, the Hessen prosecutor, began her work with the state’s Ministry of Justice to figure out how to liquidate 100 bitcoins (then worth about €200,000) that had been seized in 2014 and were just laying around.

Absent any formal process to auction the assets as local governments do all the time for seized drug dealer Lamborghinis for example, Ringwald had to personally, painstakingly, piece together a process by which her team could sell the bitcoin. Two years later she was called on again when her team grabbed the much larger 2,200 bitcoin booty from the Wall Street Market.

Since her first, highly manual sale of bitcoin, digital-asset regulation had advanced, she says, “and you could see step by step that coins were becoming more and more actual financial instruments. They’re not cars,” she says.

“So I put pressure on my boss and said, ‘I need a professional partner.’” In spite of increasing regulatory clarity in Germany, Ringwald had trouble finding institutions that actually had all of the required licenses to deal directly with crypto. So over the course of more than a year she assembled a team including two lawyers to find a qualified broker.

Enter tiny Bankhaus Scheich, which had decided that embracing digital assets could give it a strategic edge after German regulators updated rules to allow for the creation of funds tracked on “crypto securities registers.” In January 2021, the Federal Financial Supervisory Authority, known as BaFin, approved such a prospectus, allowing Bankhaus Scheich to convert European Union investment funds into assets issued on a blockchain through a process called tokenization that lets assets settle around the clock.

In pilot projects, the bank has so far tokenized real estate, private equity and a convertible bond. Nine months later, Bankhaus Scheich signed a deal with Frankfurt-based Universal Investment, which provides administration and risk-management services that allows its crypto subsidiary to trade crypto and tokenize securities for banks, asset managers, and custodians in Germany, Luxembourg and France.

Bankhaus Scheich’s crypto conversion and immersion has not been without hiccups. Recently an eight million euro tokenization pilot of a fund of funds fizzled after German neo-bank partner Nuri became insolvent in the aftermath of the FTX collapse.

Though von Schoenaich-Carolath, who is also the Tradias chief revenue officer, declined to share cost savings from cutting out securities depositories like Luxembourg-based Clearstream, it’s client Cashlink, which helps Scheich tokenize commodities and securities, put the savings at between 35% and 65%.

Before Hessen attorney Ringwald partnered with Bankhaus Schiech to clean her seized digital assets, she brought them to a crypto exchange, to see with her own eyes what would happen if the tokens were sold as they were. “The machines reacted and said, ‘this is no good,’” she recounts, “and that proved that we would have had a huge problem.”

Ringwald’s team identified Bankhaus Scheich in November of 2021 as a crypto service provider capable of legally accepting the number and variety of crypto assets Hesse had seized. A month later, the contract was signed.

To clean the funds, Ringwald first had to make sure her colleagues and bosses at the state government were okay with writing an official letter in English for international companies on German state letterhead, something that’s normally frowned upon.

In a form letter she sent to Scheich, then forwarded to Chainalysis, CoinFirm, Ellipse and other cryptocurrency blacklist creators, Ringwald confirmed her cybercrime center has the legal authority to “collect the respective purchase price” of digital currencies seized during legal proceedings, according to a copy of the letter provided to Forbes, confirms the office’s contractual relationship with Bankhaus Scheich and gives permission for the tokens to be sold to the bank.

Instead of dealing directly with exchanges that might disappear overnight, the state sells the assets directly to the bank at a discount. “We only have direct contact to Bankhaus Scheich,” says Ringwald. “Never to the market itself.” Other clients looking to trade crypto place orders directly with the bank, which fulfills the orders from its own crypto reserves.

To keep the total crypto it holds below a one million euro limit that it set after witnessing cryptobank Silvergate’s demise, the bank periodically nets the transactions with its other crypto buy and sell orders, selling them at market prices on 20 exchanges, liquidity pools and via over-the-counter (OTC) brokers that use the same security firms to check for blacklisted money.

After the buy and sell trades are netted, the position is closed out on cryptocurrency exchanges. “We don’t want to be long,” says von Schoenaich-Carolath. “We don’t want to be short.” “This white-listing process was then done for the first time in December 2021,” says Ringwald. “And then we had 100 million euros after that.”

Ironically, much of laundering process for tainted bitcoin and other dirty digital assets is accomplished manually via emails and phone calls. The whole process of cleaning tainted crypto takes about two weeks. Since its first crypto-washing cycle, the attorney general’s cybercrime unit has cleaned an additional €50 million worth of seized cryptocurrency using the Bankhaus Scheich process.

Yesterday morning in Frankfurt, Ringwald’s team, and the German Federal Criminal Police (the Bundeskriminalamt) surreptitiously acted as administrators of two servers to seize at additional 1,909 bitcoin and other cryptocurrencies along with seven terabytes of data about the operation. Germany expects to keep the proceeds of the sale of the assets, which should occur in the next week or two. “The FBI had a very big interest in this mixing service,” says Ringwald. “As many do. It was the biggest one on the dark web until yesterday.”

The funds will be turned over to the state’s Ministry of Finance and are expected to be partially used to support the state’s judicial offices, according to Ringwald. In part as a result of her work, Ringwald was appointed chair of the Hessen office on cryptocurrencies and is informally helping the other 15 German states explore ways to deal with dirty crypto.

“What is happening now in Germany is that other states are adopting that,” says Ringwald. Von Schoenaich-Carolath says two states have already signed a deal with the bank but declined to name them. In addition to its German state clients, Bankhaus Scheich is working with more than 30 institutions offering it other blockchain services, including, traditional securities exchange Börse Stuttgart, broker Trade Republic and Deutsche Telekom.

While some crypto initiatives, including a bitcoin exchange-traded note with Fidelity International, are run from the main bank offices, the majority are housed at subsidiary Tradias, which has grown to nearly 100 employees from just 10 a year ago. Chief Executive Beck owns 100% of Bankhaus Scheich and 60% of Tradias, with the other 40% owned by his son Christopher, who is the subsidiary’s CEO.

In February, the bank filed its annual statement for 2021, showing €14 million in crypto trading revenue, representing roughly a third of the €47 million in total trading income that year, compared to almost nothing the year before. That also doesn’t count Tradias’ revenue, which is not disclosed.

Given Bankhaus Scheich’s crypto-trading operation and the fact that it sells most of the crypto it cleans back to various crypto exchanges around the world, it maintains accounts at many of them. One of them happened to be recently shuttered FTX. In November, along with most of FTX’s other customers, the exchange froze Bankhaus Scheich’s funds, including about €2 million worth of bitcoin, ether and stablecoins.

The German bank is suing FTX, but the global exchange’s collapse may wind up bringing new business to Bankhaus Scheich as mainstream companies seek third parties to represent them in their crypto trading and tokenization efforts. “The clients now understood after FTX that there’s something like counterparty risk in the market,” says von Schoenaich-Carolath, who admits to already signing up three new clients that were formerly considering working with FTX.

“We put our money in 20 different baskets within our risk limits,” he says. “And when we lose some, nothing happens.” It’s possible that FTX’s collapse could create billions more in cryptocurrencies in need of cleansing, depending on which seized assets analytics firms decide to blacklist.

It is clear that U.S. regulators have prioritized enforcement over establishing clear regulatory rules and that’s likely to result in more crackdowns, seizures and untradeable crypto. In fact, in January, the U.S. Federal Reserve Board, the Federal Deposit Insurance Corp., and the Office of the Comptroller of the Currency issued a rare joint statement warning banks about the “vulnerabilities related to cyber-attacks, outages, lost or trapped assets, and illicit finance” and seizures and forfeitures are expected to increase as regulators around the world crack down on illegal uses of cryptocurrency.

All of this could be good news for Bankhaus Scheich, its in house crypto specialist Tradias and its budding digital asset laundry.