You have policies but unclear processes
Your team needs to connect the written rules to daily onboarding and transactions.
Operate With Confidence
AML/CFT Compliance for Crypto Businesses
A policy pack is only a starting point. Check how customers join, how assets move and who responds when something needs attention, then align the documents with those steps.
At a glance
Is this the right service?
Crypto businesses reviewing compliance before launch, licensing, banking or an operational change.
What it can cover
- Customer and transaction review
- Control gap assessment
- Policy and procedure work
- Transfer-information questions
01 · Check the fit
When this service fits
The business model has changed
New users, markets, wallets or products need to be reflected in the review.
A bank or regulator has questions
You need to organise the relevant controls, records and responsibilities.
02 · What we can help with
What the work covers
Customer and transaction review
Map users, counterparties, wallets, jurisdictions and asset flows.
Control gap assessment
Review onboarding, monitoring, screening, escalation and recordkeeping against the agreed requirements.
Policy and procedure work
Prepare or review the documents that explain how the controls operate and who is responsible.
Transfer-information questions
Assess which transfer-information rules need review for the proposed flows and counterparties.
03 · How to get started
What to bring
Start with what you have. These details help frame the first discussion.
Send the basics
- Current policies and customer onboarding flows
- Transaction, wallet and counterparty maps
- Responsibility charts and any bank or regulator requests
Then define the scope
Focus the first conversation on the decision you need to make.
Applicable obligations depend on the activity and jurisdiction. A document review is not certification that the business is compliant.
Get Expert Advice04 · See related matters
How Ape Law approached similar questions
These published matters show the decision process. Another project's facts, rules and outcome may differ.
05 · Common questions
Common questions
Is this only a KYC document review?
No. The scope can also examine transaction flows, monitoring, sanctions, escalation, governance and the records behind those processes.
Can you review policies prepared by another provider?
Yes. The question is whether they fit the actual business and whether the team can explain how they are used.
Do you operate our compliance function?
Advisory and document work should be distinguished from day-to-day monitoring or an appointed compliance role. Any operational responsibilities need a separate agreement.
Do your controls match how the business works?
Describe the activity, existing policies and the questions that prompted the review.
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