Financial Crime Compliance

Crypto-asset financial crime compliance is a distinct discipline from traditional AML compliance. The threat landscape is different: on-chain transactions are traceable but pseudonymous; DeFi protocols can move value faster than monitoring tools can generate alerts; state-sponsored actors use crypto at scale for sanctions evasion and theft.

Effective crypto financial crime compliance requires a tool stack that includes blockchain analytics for address attribution, transaction monitoring for pattern detection, sanctions screening for both customer and wallet data, and a case management system that correlates signals across tools. The integration of these tools — operational orchestration — is what AMLA's supervisory methodology will assess.

The FATF Travel Rule adds a cross-institution dimension: CASPs must screen counterparty VASP AML standards before processing transfers, and must transmit originator data that itself must be screened at the receiving end. This creates an ongoing counterparty due diligence obligation that is distinct from customer CDD.