Compliance, Remediation and Investigations for Crypto Exchanges
For exchanges, brokers, OTC desks, custodians and other virtual asset service providers (VASPs). We help compliance teams build controls that hold up to regulators, bank partners and auditors, fix what an exam or audit found, and investigate when funds move where they should not.
Remediation
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KYC/KYB file remediation: refreshing, validating and reconciling customer and business files, including beneficial ownership, source of funds and risk ratings
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Regulatory and audit findings: action plans and evidence for findings from state money transmitter exams, FinCEN, FINTRAC, other regulators, bank partner reviews and internal audits
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Lookbacks: reviewing historical transactions and alerts when a regulator, bank partner or your own testing calls for it
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Monitoring tuning: blockchain analytics and transaction-monitoring scenarios, thresholds and alert workflows
Compliance programs
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AML/KYC program design: policies, procedures and an enterprise-wide risk assessment
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Travel Rule, sanctions screening and wallet-screening controls
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Preparation for licensing, registration and bank partner due diligence
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Training for compliance analysts, investigators and senior management
Independent testing and reviews
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Independent AML testing: the periodic independent review your AML program needs, with sample testing of KYC files, monitoring alerts, screening and training records, and a written report of findings
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Sanctions program reviews: customer and wallet-address screening, list coverage, how alerts are cleared and documented, and blocking and rejection procedures
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Exam readiness: a mock review before a state, regulator or bank partner examination, so gaps are found and fixed first
Investigations
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Hacks, thefts and exploits: tracing outflows and identifying the exchanges holding the funds
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Customer fraud and scam typologies affecting your platform
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Support with law-enforcement requests, subpoenas and freezing orders
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Analyst reports and affidavits when a matter goes to court
How it works
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Conflict check. Tell us your firm, the counterparties involved and the scope.
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Scoping. A written proposal with deliverables, timeline and a fixed or capped fee.
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Delivery. A named lead, regular check-ins and documented working papers.
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Handover. Findings, evidence and recommendations your team and examiners can follow.
Independence. If we design or remediate part of your program, we will not perform the independent test of that work. Independent testing is offered only where we have had no role in building or fixing what is being tested.
Read more about our AML, KYC and remediation advisory, or email info@complychainsolutions.com with a short description of what you need.
