What could they do though? Ask all employees to provide their personal wallet addresses then monitor that? Seems unlikely to happen.
So, yeah, this is exactly what coin base should be doing. They should require all employees to list all account addresses they have access to.
It's a trivial ask for the employee and its trivial to scan
but the point is two fold.
One: you've done your diligence so as a company you've covered your ass with the regulators.
Two: you've made it clear to the employee what the rules are, if they chose to open a new brokerage account or wallet address then they clearly know they are breaking the rules so there is no confusion.
as one compliance officer said to me, the regulators aren't looking for perfection, they are looking to see that you are following both the rule you laid out in your internal policies and that you are doing what the rest of the industry does.
Most serious hedge funds won’t even allow you to bring your cellphone inside the trading pit.
Crypto needs to grow up and accept regulation too if it wants to be taken seriously as an industry.