According to Dossier, an OTC called Bankoff is operating from an office owned by a company directed by Lugovoi’s wife, Ksenia. Bankoff appears to be the most active trader on Binance’s peer-to-peer marketplace for deals with Russian ruble, with the highest daily trading volumes, according to Dossier’s research. The almost non-existent know-your-customer/anti-money laundering (KYC/AML) procedures allow users to buy and sell crypto via Bankoff without revealing their identity, Dossier said. (An OTC is a broker-dealer as opposed to a centralized exchange.)