COMPLIANCE
Compliance, financial crime, and regulatory risk.
Aethemis advises digital asset and fintech businesses on the compliance programs, licensing structures, and risk frameworks that regulators expect and enforcement actions test. Our advisory draws on direct experience inside the firms, exchanges, and financial institutions our clients are now operating in or against.
01 — VASP compliance
Fintech compliance
Virtual-asset service providers and fintech companies face licensing, registration, and compliance obligations across every jurisdiction where they operate or have customers. Requirements differ significantly between the U.S., EU, UK, and APAC, and continue to evolve as regulators implement FATF standards and domestic frameworks. Aethemis advises fintechs on licensing strategy, program design, and ongoing compliance across global markets.
End-to-end fintech compliance advisory
End-to-end advisory on fintech compliance obligations, including program design, policy frameworks, regulator engagement, and remediation for businesses at any stage of the licensing lifecycle.
Strategic regulatory advisory
Strategic regulatory advisory for fintech companies navigating registration requirements, supervisory expectations, and cross-border compliance obligations across multiple frameworks simultaneously.
02 — AML and financial crime
AML and financial crime compliance
AML compliance in digital assets requires more than a policy document. Regulators and enforcement agencies expect programs that are operationally effective, technologically current, and defensible under scrutiny. Aethemis designs and reviews AML programs for crypto exchanges, fintech platforms, and financial institutions, drawing on direct experience building these functions from the inside.
Crypto AML compliance
Advisory on the design, implementation, and review of AML compliance programs for cryptocurrency businesses, including exchanges, custodians, and payment platforms. BSA/AML program design and ongoing compliance advisory for digital asset businesses with obligations under U.S. federal and state frameworks, EU requirements, and analogous global standards.
AML compliance fintech
AML program design and review for fintech platforms, covering customer due diligence, enhanced due diligence, suspicious activity reporting, and regulator engagement.
Crypto KYC advisor
KYC program design and review, including customer identification, beneficial ownership, risk-based due diligence, and ongoing monitoring frameworks for digital asset businesses.
Transaction monitoring advisory
Transaction monitoring framework design, rules calibration, alert management, and technology assessment for crypto exchanges and fintech platforms with high-volume transaction flows.
Crypto AML program
Structured AML program build-outs for crypto businesses, covering written policies, risk assessments, training, independent testing, and the designated compliance officer function.
Anti-money laundering
AML advisory across the full spectrum of obligations, from initial program design and risk assessment through to internal audit support, regulatory examination preparation, and enforcement response.
03 — Sanctions compliance
Sanctions compliance
Sanctions exposure in digital assets is not limited to direct transactions with sanctioned parties. Regulators and enforcement agencies increasingly focus on the controls firms have in place, the adequacy of their screening programs, and their response when exposure is identified. Aethemis advises crypto businesses and fintech platforms on sanctions compliance program design, OFAC engagement, and enforcement response.
Sanctions compliance crypto
Sanctions compliance program design and review for cryptocurrency businesses, covering screening obligations, control frameworks, voluntary self-disclosure considerations, and regulator engagement.
OFAC compliance crypto
Advisory on OFAC obligations for digital asset businesses, including SDN screening, compliance program requirements, license applications, and response to OFAC inquiries or enforcement actions.
Sanctions screening crypto
Screening program design, technology assessment, and operational framework review for crypto platforms with obligations to screen customers, transactions, and wallet addresses against sanctions lists.
Crypto sanctions advisory
Strategic advisory on sanctions risk in digital asset operations, including jurisdiction-specific exposure analysis, compliance gap assessment, and remediation planning.
DeFi sanctions compliance
Sanctions risk analysis and compliance advisory for DeFi protocols, DAO operators, and infrastructure providers navigating OFAC and international sanctions obligations in decentralised environments.
04 — Monitorships
Monitorships
Compliance monitorships arise in the context of regulatory settlements, enforcement actions, and consent orders where an independent monitor is required to oversee a firm's remediation. Aethemis advises businesses entering monitorship arrangements, supports monitor selection and engagement processes, and provides strategic guidance throughout the remediation period.
Crypto monitorship
Advisory and support for cryptocurrency businesses subject to compliance monitorships, including regulator engagement, remediation planning, and monitor relationship management.
Compliance monitor crypto
Independent compliance monitoring and advisory for digital asset businesses operating under regulatory consent orders, settlement agreements, or voluntary remediation frameworks.
Independent compliance monitor fintech
Independent compliance monitoring engagements for fintech businesses, covering program assessment, remediation tracking, and reporting to regulators or relevant oversight bodies.
05 — Crypto exchanges
Crypto exchanges
Cryptocurrency exchanges operate under some of the most demanding compliance obligations in financial services, combining money transmission licensing, BSA/AML requirements, sanctions screening, and market integrity rules across multiple jurisdictions. Aethemis advises exchanges on compliance program design, licensing strategy, and regulatory engagement, drawing on direct experience building and running compliance functions inside major digital asset platforms.
Crypto exchange compliance
Compliance program design, review, and ongoing advisory for cryptocurrency exchanges, covering AML/KYC, sanctions screening, transaction monitoring, and regulatory reporting obligations.
Crypto exchange regulatory counsel
Legal and regulatory counsel for exchanges navigating licensing requirements, regulator engagement, enforcement risk, and compliance program obligations across target jurisdictions.
Crypto exchange legal advisor
Legal advisory on exchange operations, product structuring, market integrity obligations, and regulatory positioning across the U.S., EU, UK, and APAC markets.
06 — Stablecoin issuers
Token issuers
Token issuers face a rapidly evolving set of regulatory requirements across reserve management, licensing, disclosure, and consumer protection. Regulatory frameworks in the U.S., EU, and UK are at different stages of development and impose materially different obligations. Aethemis advises issuers on compliance program design and licensing strategy as those frameworks take shape.
Token issuer compliance
Compliance program design and ongoing advisory for stablecoin issuers, covering reserve management, disclosure obligations, AML/KYC requirements, and regulatory reporting across applicable jurisdictions.
Token licensing
Licensing strategy, application management, and regulator engagement for token issuers seeking authorisation under U.S. federal and state frameworks, EU MiCA, UK Payment Services Regulations, and APAC regimes.
07 — Banks and financial institutions
Banks and financial institutions
Banks and financial institutions engaging with digital assets face regulatory scrutiny from multiple directions, including prudential regulators, AML supervisors, and consumer protection bodies. Aethemis advises financial institutions on how to structure digital asset engagement, build the required compliance infrastructure, and manage the regulatory relationships that come with it.
Bank crypto compliance
Compliance advisory for banks and financial institutions engaging with cryptocurrency, covering BSA/AML obligations, customer due diligence for crypto clients, and regulatory approval processes for digital asset activities.
Bank digital asset strategy
Strategic advisory for financial institutions developing digital asset products, custody services, or payment infrastructure, covering regulatory positioning, licensing requirements, and compliance program design.
08 — Fintech and payments
Fintech and payments
Payments businesses operate at the intersection of money transmission licensing, AML obligations, and consumer protection requirements that vary materially across jurisdictions. Aethemis advises fintech and payments companies on regulatory strategy, compliance program design, and licensing across the markets where they operate.
Payments regulatory advisor
Regulatory advisory for payments businesses navigating licensing, AML compliance, and ongoing supervisory obligations across U.S. federal and state, EU, UK, and APAC frameworks.
Fintech payments compliance
Compliance program design and ongoing advisory for fintech payments platforms, covering money transmission obligations, AML/KYC requirements, sanctions screening, and regulatory reporting.
09 — Building a crypto AML program
Building a crypto AML program
An effective crypto AML program is not a static document. It is an operational function that needs to be calibrated to the business, defensible under regulatory scrutiny, and capable of evolving as the risk environment changes. Aethemis advises businesses on how to build, review, and remediate AML programs that meet regulatory expectations and hold up in practice.
Crypto AML program template
Structured AML program frameworks for crypto businesses, covering written policies, risk assessment methodology, customer due diligence procedures, suspicious activity reporting, and independent testing requirements.
AML program design and build-out
End-to-end advisory on AML program design for digital asset businesses, from initial risk assessment and policy development through to implementation, staff training, and regulatory examination readiness.
Crypto AML requirements
Analysis of AML compliance requirements for crypto businesses across applicable jurisdictions, including FinCEN registration, BSA obligations, EU AMLD requirements, and equivalent international standards.
Transaction monitoring for crypto exchanges
Transaction monitoring program design for cryptocurrency exchanges, covering rule development, alert management, case investigation workflows, and technology assessment against supervisory expectations.
10 — Cross-border crypto compliance
Cross-border crypto compliance
Operating a digital asset business across multiple jurisdictions means managing compliance obligations that overlap, conflict, and evolve at different rates. Aethemis provides integrated cross-border compliance advisory, giving businesses a single coherent view of how their obligations interact rather than jurisdiction-by-jurisdiction analysis that leaves gaps at the seams.
Cross-border crypto compliance playbook
Structured compliance frameworks for digital asset businesses operating across multiple jurisdictions, covering how AML, sanctions, licensing, and reporting obligations interact across target markets.
Multi-jurisdiction crypto compliance
Cross-border compliance program design and ongoing advisory for crypto businesses with operations, customers, or licensing obligations across more than one regulatory framework.
Global crypto licensing guide
Comparative licensing analysis and strategic sequencing advisory for crypto businesses planning market entry or expansion across the U.S., EU, UK, and APAC jurisdictions.
11 — OFAC and sanctions compliance for digital assets
OFAC and sanctions compliance for digital assets
OFAC has made clear that digital asset businesses are subject to U.S. sanctions obligations regardless of where they are incorporated or where their customers are located. Enforcement actions against crypto businesses have involved civil penalties, blocked transactions, and reputational consequences that extend well beyond the initial action. Aethemis advises digital asset businesses on OFAC compliance program design, voluntary self-disclosure, and enforcement response.
OFAC guidance crypto
Advisory on OFAC's published guidance for digital asset businesses, including the 2021 sanctions compliance guidance, SDN list screening obligations, and the application of existing sanctions frameworks to on-chain activity.
Sanctions compliance program crypto
OFAC sanctions compliance program design for crypto businesses, covering risk assessment, screening controls, escalation procedures, recordkeeping, and senior management oversight requirements.
OFAC digital assets compliance
End-to-end OFAC compliance advisory for digital asset businesses, from initial program design through to voluntary self-disclosure considerations, licence applications, and enforcement response.
