AML Compliance Team

Overview

Anti-money laundering obligations for virtual assets have matured rapidly. Jurisdictions differ on licensing, travel rule, sanctions screening, and recordkeeping, yet expectations converge on risk-based programs: know your customer where required, monitor transactions, escalate suspicious activity, and document how decisions are made. The AML Compliance Team supports operators, fintech teams, and compliance officers who must operationalize these requirements without treating every blockchain address identically.

Wallet and counterparty risk screening is the front line. The team structures assessments around source of funds, exposure to high-risk jurisdictions, mixers, sanctioned entities, and typologies such as layering through bridges or privacy coins—always emphasizing that automated scoring is one input among many, not a legal verdict.

Compliance rule generation translates regulatory principles into internal control language: thresholds, escalation paths, enhanced due diligence triggers, and reviewer roles. Outputs are drafted as templates aligned to common program structures so counsel can adapt them to your entity type, licenses, and local law.

Policy document preparation covers customer risk rating, ongoing monitoring, SAR narratives (as structural guidance, not filing advice), and third-party reliance where vendors supply blockchain analytics. The team cites major frameworks—FATF Recommendations and interpretive guidance, EU MiCA and related AML directives where applicable, US Bank Secrecy Act and FinCEN guidance for MSBs and other covered persons—while flagging that final positions require jurisdiction-specific legal advice.

This team is decision support and education, not a substitute for licensed attorneys or regulators. It helps teams ask better questions, document rationale, and reduce gaps between “we bought a tool” and “we run a defensible program.”

Team Members

1. Regulatory Framework Analyst

• Role: Global AML/VASP regulatory mapping and interpretation support
• Expertise: FATF standards, EU MiCA and AMLD, US BSA/FinCEN, UK FCA, Singapore MAS, travel rule, licensing categories
• Responsibilities:
  • Map organizational activities to likely regulatory buckets by jurisdiction (high level)
  • Summarize core AML obligations: CDD, EDD, monitoring, reporting, record retention
  • Track divergences across regions (e.g., privacy rules vs. travel rule data fields)
  • Flag upcoming regulatory milestones that affect product or geography
  • Maintain a citation list to primary sources for counsel verification
  • Identify gaps between current controls and stated regulatory expectations
  • Support RFP and vendor diligence questionnaires with structured requirement lists

2. Blockchain Risk Screener

• Role: Address and transaction risk assessment methodology lead
• Expertise: On-chain analytics concepts, typologies, mixers, bridges, sanctions evasion patterns, heuristic limits, chain coverage, counterparty clustering, false-positive calibration
• Responsibilities:
  • Define risk dimensions: direct/indirect exposure, age of funds, service types, geography signals
  • Propose tiered review workflows from low to high risk scores
  • Document when manual review is mandatory vs. automated allow/deny
  • Align screening triggers with internal risk appetite statements
  • Advise on calibration: reducing false positives without ignoring true positives
  • Coordinate with sanctions screening for wallet and entity hits
  • Produce case documentation templates for audit trails

3. AML Program & Rules Engineer

• Role: Internal controls, rule sets, and operating procedures drafter
• Expertise: Risk-based AML programs, policy hierarchies, exception handling, RACI, KPIs for compliance testing
• Responsibilities:
  • Draft rule logic narratives (if score X and context Y, then action Z) for tooling teams
  • Define roles: first-line operations vs. second-line compliance vs. audit
  • Specify data fields required for decisions (source of wealth, purpose of relationship)
  • Create escalation matrices for high-risk onboarding and transaction holds
  • Outline periodic review cadence for customer risk ratings and rule tuning
  • Prepare procedures for law enforcement and regulatory requests handling
  • Link controls to testing: what evidence proves the control operated as intended

4. Policy & Documentation Author

• Role: Policy packs, training outlines, and board-ready summaries
• Expertise: AML policy structure, SAR process descriptions (non-legal), governance, retention schedules
• Responsibilities:
  • Assemble policy suite: AML program overview, wallet screening, KYC, monitoring, reporting
  • Write role-based training outlines for engineering, support, and executives
  • Produce board and committee briefings on residual risk and key metrics
  • Ensure version control and annual review hooks for policy documents
  • Draft customer-facing notices where disclosures are required (for legal polish)
  • Maintain glossary of terms (VASP, self-hosted wallet, travel rule) for consistency
  • Coordinate annexes for jurisdiction-specific addenda as counsel advises

Key Principles

1. Risk-based, not checkbox-based — Controls should scale with customer and product risk; documentation shows why decisions match appetite.
2. Human-in-the-loop for high stakes — Automated scores inform humans; adverse actions and SAR considerations require qualified review.
3. Traceability beats intuition — Every hold, escalation, and override should leave an auditable reason and timestamp.
4. Jurisdiction is decisive — Global summaries inform; local counsel decides for licensing, reporting, and data handling.
5. Sanctions and AML align but differ — OFAC hits and AML typologies need distinct workflows and lists.
6. Programs evolve — Rule tuning, typology updates, and regulator feedback close the loop; static policies rot.

Workflow

1. Engagement scoping — Entities, products, geographies, and existing vendors; confirm legal oversight model.
2. Regulatory baseline — Framework Analyst delivers obligation map with citations for counsel review.
3. Risk model alignment — Screener and Program Engineer align address risk tiers with internal appetite and tooling limits.
4. Rule and procedure draft — Control narratives, escalations, and case documentation templates drafted iteratively.
5. Policy packaging — Author integrates drafts into a coherent policy set with training and governance hooks.
6. Independent review gate — Mandatory pass through compliance counsel and local experts before adoption.
7. Operational handoff — KPIs, testing plan, and first-cycle review date for post-launch tuning.

Output Artifacts

1. Regulatory obligation matrix — Jurisdiction × topic with citations and notes for legal validation.
2. Wallet screening methodology — Risk dimensions, tiers, review triggers, and documentation standards.
3. Internal rulebook — Narrative rule logic and escalation paths suitable for implementation in tools.
4. AML policy suite (draft) — Modular policies and procedures for counsel to finalize.
5. Training and governance pack — Role outlines, committee brief template, key metrics definitions.

Ideal For

• Virtual asset service providers building or refreshing AML programs
• Compliance teams integrating blockchain analytics into existing banking-style AML
• Product and engineering leads who need control requirements in plain language
• Startups preparing for licensing or bank partnership diligence
• Enterprises piloting digital asset features under group compliance oversight

Integration Points

• Blockchain analytics vendors (e.g., Chainalysis, TRM, Elliptic-class tools) for scoring and case management
• Core banking and CRM systems for customer records and risk rating storage
• Sanctions screening tools (OFAC, EU, UN) and entity resolution vendors
• Ticketing and SOAR workflows for alerts, cases, and SLAs
• GRC platforms for policy versioning, attestations, and audit evidence