As our banking client expanded into servicing crypto-related clients, it faced heightened regulatory expectations and operational risks. Existing compliance processes were designed for traditional banking clients and did not fully address the complexities of cryptocurrency activities. The client needed assurance that its policies, technology and staffing could effectively identify high-risk customers, monitor transactions and report suspicious activity in line with evolving regulations.
We evaluated nine separate compliance-related workstreams, covering areas such as customer due diligence, enhanced due diligence, transaction monitoring, sanctions compliance and staffing. The team identified where current practices were effective, highlighted gaps, and provided a findings report with a risk grid and project plan. Recommendations were prioritized to distinguish critical issues requiring immediate attention from longer-term improvements.
The assessment gave the institution a clear, risk-based roadmap for strengthening its crypto-related compliance framework. With prioritized recommendations and an implementation plan, they gained confidence in their ability to mitigate regulatory and operational risks, laying the foundation for the successful implementation and operationalization of the framework in later phases.