Stay Out Of Trouble
AML/CFT Compliance for Crypto Businesses
For crypto exchanges, brokers, custodians, token projects, fintechs, and virtual asset businesses, Ape Law helps review AML/CFT exposure, customer onboarding, transaction monitoring, sanctions controls, Travel Rule planning, and compliance documentation before regulators, banks, or counterparties start asking hard questions.
Best for
VASPs, crypto exchanges, brokers, custodians, transfer services, token platforms, fintechs, and Web3 businesses handling virtual asset activity
Primary outcome
AML/CFT risk assessment, policy review, onboarding controls, Travel Rule planning, sanctions screening, monitoring, and compliance documentation
Reviewed by
Ape Law legal team
You are probably here because
If one of these sounds familiar, the compliance structure should be reviewed before onboarding users, opening bank accounts, applying for licenses, or scaling transaction volume.
You need AML/CFT documents that match your crypto business model.
Generic compliance templates often miss wallet flows, customer risk, transaction monitoring, sanctions exposure, Travel Rule planning, and virtual asset-specific controls.
A bank, regulator, exchange, or partner is asking compliance questions.
Ape Law helps review the legal position, policy gaps, risk assessment, onboarding flow, and documents needed to respond with a clearer compliance posture.
You want to avoid compliance gaps before launch or licensing.
Weak AML/CFT controls can create licensing delays, banking friction, partner concerns, account restrictions, or regulator questions.
What Ape Law helps with
The work is focused on turning crypto compliance risk into a clear AML/CFT framework that supports licensing, banking, onboarding, and operations.
Risk assessment
Review customer types, jurisdictions, products, transaction flows, wallet exposure, counterparties, sanctions risk, and virtual asset activity.
Policies and procedures
Review or prepare AML/CFT policies, onboarding procedures, escalation steps, suspicious activity processes, recordkeeping, and governance documents.
Travel Rule planning
Assess virtual asset transfer flows, originator and beneficiary information handling, counterparty VASP issues, wallet controls, and operational readiness.
Compliance readiness
Identify gaps that could affect licensing, banking, regulator responses, exchange relationships, customer onboarding, or ongoing monitoring.
How the engagement works
The engagement turns unclear AML/CFT exposure into a practical compliance roadmap with clear documents, controls, gaps, and next steps.
1. Intake
What happens
We understand the business model, virtual asset activity, customer base, jurisdictions, wallet flows, transaction types, and compliance status.
What Ape Law needs
Business description, product flows, customer journey, transaction flow, wallet model, current policies, risk assessment, and launch or licensing timeline.
Output
Initial AML/CFT issue map and fit assessment.
2. Gap review
What happens
We review existing AML/CFT documents, onboarding controls, sanctions screening, transaction monitoring, Travel Rule planning, and governance materials.
What Ape Law needs
AML policy, CDD/KYC procedures, sanctions process, monitoring rules, escalation process, Travel Rule plan, and compliance team information.
Output
Compliance gap map and priority list.
3. Control plan
What happens
We map the policies, procedures, governance steps, risk controls, documentation, and operational changes needed to support the business.
What Ape Law needs
Risk appetite, operating model, technology stack, vendor information, partner requirements, regulator questions, and banking expectations.
Output
AML/CFT compliance roadmap and document action list.
4. Document support
What happens
We support the preparation, review, and refinement of compliance documents, response materials, and regulator or banking-facing explanations.
What Ape Law needs
Draft policies, internal procedures, onboarding screens, monitoring workflows, governance documents, and external requests where available.
Output
Document comments, compliance language, response strategy, and next legal steps.
AML/CFT pathway and risk drivers
These are the issues that usually determine whether a crypto compliance framework is credible, incomplete, or likely to create regulatory or banking friction.
Pathway map
1. Business activity
What virtual asset activity does the business perform, and what AML/CFT risks does that activity create?
2. Customer and counterparty risk
Who are the users, counterparties, wallets, VASPs, partners, issuers, investors, and jurisdictions involved?
3. Control framework
What onboarding, monitoring, sanctions, Travel Rule, escalation, governance, and recordkeeping controls are already in place?
4. Readiness route
What needs to be fixed before licensing, banking, launch, partner review, or regulator-facing submissions?
What can make this complex
1. Cross-border users
Users, wallets, counterparties, issuers, and VASPs across multiple jurisdictions can change the risk profile quickly.
2. Wallet and transaction flows
Hosted wallets, unhosted wallets, transfers, swaps, custody, deposits, withdrawals, and settlement flows need clear controls.
3. Travel Rule readiness
Virtual asset transfers may require originator and beneficiary information handling, counterparty VASP assessment, and operational planning.
4. Sanctions and suspicious activity
Screening, monitoring, escalation, suspicious activity indicators, and recordkeeping need to fit crypto-specific risk patterns.
5. Banking and licensing pressure
Banks, regulators, and partners often expect compliance documents to match the actual business model, not a generic policy pack.
Common mistakes this service helps prevent
Most AML/CFT problems are easier to fix before launch, licensing, or bank review. The goal is to close gaps before they become blockers.
Using generic AML templates for a crypto business.
A generic policy may not address wallet flows, Travel Rule planning, blockchain monitoring, sanctions exposure, counterparty VASPs, or crypto-specific red flags.
Treating onboarding as the whole compliance program.
KYC is only one part. Crypto businesses also need risk assessment, monitoring, sanctions controls, escalation procedures, governance, and recordkeeping.
Waiting until a bank or regulator asks for documents.
Compliance gaps are harder to fix under pressure, especially when licensing, banking, partner onboarding, or account access depends on the answer.
Review AML/CFT Compliance
Built for crypto-native teams that need practical compliance judgment
Ape Law works with crypto, Web3, tokenization, payments, and digital asset teams that need AML/CFT advice tied to how the business actually onboards users, moves assets, monitors activity, and responds to regulators, banks, and partners.
Reviewed by Ape Law legal team
Content and structure reviewed by crypto-native legal professionals.
AML/CFT, Travel Rule, licensing, and banking experience
Legal support for risk assessments, compliance policies, onboarding controls, virtual asset transfer issues, banking questions, and regulator-facing materials.
Anonymized project experience
Built from real crypto compliance, licensing, banking, regulatory, and operational work.
Next step
Need AML/CFT controls that match your crypto business?
Send the business model, user flow, wallet structure, and existing compliance documents. Ape Law will help identify AML/CFT gaps, regulatory risks, document needs, and next steps.