Crypto touches AML, sanctions, securities, consumer protection, tax reporting—depth varies materially by corridor.
Risk assessments
Document geographic footprint, customer archetypes, asset universe, counterparties, and residual risks after mitigations.
Refresh cadences when products, chains, or jurisprudence shift materially.
Customer diligence
KYB/KYC tiers may apply depending on thresholds—capture rationale for simplified vs enhanced diligence.
Ongoing monitoring beats point-in-time onboarding screens.
Reporting & cooperation
Suspicious activity narratives, traveler rule analogs where relevant, mutual legal assistance timelines—coordinate internal legal before contacting authorities.
Retain immutable audit trails respecting privacy minimization.
Governance hygiene
Board-level accountability, written policies, periodic training, metrics on alerts vs false positives—demonstrate maturity during examinations.
Vendor diligence extends to custodial partners or RPC providers touching regulated flows.
Last updated: April 2026
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