Compliance
Compliance systems for crypto, fintech and cross-border businesses.
We build and adapt compliance frameworks that regulators, banks and institutional partners expect: AML/KYC, sanctions controls,
governance, risk management, outsourcing controls and operational procedures — with an emphasis on implementation, not “paper”.
If you are preparing for licensing, we align policies and procedures with the regulator’s rulebook and your operating model.
What “good compliance” looks like
- Controls match real transaction flows.
- Clear roles: MLRO/Compliance, escalation, reporting.
- Documented onboarding + ongoing monitoring logic.
- Outsourcing and technology risks are addressed.
Often combined with Crypto licensing.
Deliverables
Compliance deliverables we prepare
Scope depends on your risk profile and whether you are regulated. Below is a standard baseline used for many fintech and digital asset projects.
Core
AML/KYC framework
Policies and procedures for onboarding, monitoring and reporting.
- AML/CFT Policy (risk-based approach).
- CDD/EDD rules and client risk scoring logic.
- Ongoing monitoring and suspicious activity escalation.
- Recordkeeping and reporting workflow.
Typical trigger: licensing, banking, institutional partnerships.
Core
Sanctions & screening controls
Practical rules for lists, screening frequency and escalation.
- Sanctions Policy and screening workflow.
- PEP/adverse media checks baseline.
- Blocked/frozen asset handling logic (where relevant).
- Audit trail and evidence retention rules.
Critical for cross-border payments and crypto flows.
Core
Compliance manual & governance
Roles, controls, reporting lines and independence rules.
- Compliance Manual with responsibilities.
- MLRO/CO role description and delegation.
- Internal reporting cadence and KPIs.
- Conflicts and gifts/benefits rules (if needed).
Often requested by regulators and institutions.
Add-on
Risk management framework
A clear risk map that matches your operations and outsourcing.
- Risk taxonomy and risk appetite baseline.
- Operational, tech, custody and fraud risks.
- Controls mapping and reporting rules.
- Incident management and remediation plan.
Useful for regulated models and serious partnerships.
Add-on
Onboarding procedures
Step-by-step onboarding that can be implemented by your team.
- Client onboarding SOPs (retail/pro).
- Source of funds/wealth evidence rules.
- Wallet/travel rule baseline (if relevant).
- Periodic review procedures for existing clients.
Most projects fail on execution, not policy text.
Add-on
BCP & outsourcing controls
Operational resilience and vendor control framework.
- Business Continuity Plan baseline.
- Outsourcing policy and vendor due diligence.
- Technology risk and access management rules.
- Incident response and internal escalation.
Important for custody, exchanges and regulated tech stacks.
Approach
How we build compliance (so it works)
Compliance must match real flows: onboarding, transaction monitoring, custody, fiat rails, counterparties and outsourcing.
We map operations first and only then write documents.
What we map first
- Client types (retail/pro), geographies and risk exposures.
- Flow of funds and assets (fiat rails, wallets, custody).
- Counterparties: banks, PSPs, liquidity providers, custodians.
- Outsourcing and technology stack responsibilities.
Output: a controls map showing “who does what”, evidence, escalation and reporting lines.
Typical engagement paths
Banking readiness
AML/KYC + sanctions → onboarding SOPs → evidence pack for bank/PSP.
Licensing readiness
Compliance manual + risk framework → policies set → application narrative alignment.
Operational scale
Automation rules → periodic reviews → audits, KPIs and reporting cadence.
Existing business clean-up
Gap analysis → rewrite policies → team training baseline → monitoring improvements.
Related: Corporate and
Crypto licensing.
FAQ
Common questions
Short answers. For regulated routes, we align with the applicable rulebook and guidance.
Can we use “template AML policy” from the internet?
You can, but it usually fails in practice: it won’t match your flows, roles and evidence trail — and regulators/banks will see that quickly. We build a framework that you can actually execute.
Do you help with MLRO/Compliance role setup?
Yes. We can define responsibilities, reporting cadence, independence and escalation rules, and align them with your team structure.
What do banks usually ask for first?
Clear AML/KYC + sanctions controls, onboarding procedures, evidence trail, and understanding of your counterparties and transaction flows.
Do you support audits and regulator Q&A?
Yes. We help structure responses, provide documentation support and adjust policies when comments require operational changes.
Need a compliance pack that actually works?
Send a short description: what you do, target markets, whether you hold client assets, and your banking/licensing goals.
We will propose a structured compliance scope and the first deliverables.
If you already have policies, we can run a gap analysis and rebuild only what is missing.
Good fit for this service:
- Crypto/fintech businesses onboarding clients globally.
- Projects preparing for licensing or bank/PSP onboarding.
- Teams needing implementable onboarding & monitoring procedures.
- Companies with outsourcing-heavy tech stacks and custody dependencies.
We focus on mapping controls to real flows — that’s what regulators and banks care about.