ROCA is already showing up in Binance job specs: auto-decision thresholds, TP/TN/FP/FN labeling, >95% precision and >99% recall across KYC, ATO, 2FA resets and withdrawal anomaly queues. If that works, the moat is cheaper compliance per user while Binance still runs a 1,500-person compliance machine under DOJ/FinCEN monitor pressure. If thresholds drift, users eat account freezes and false AML hits at exchange scale.

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