REGULATORY ADVISORY
Crypto AML compliance built by the people who have built it before.
Aethemis advises crypto exchanges, custodians, payment providers, and digital asset businesses on AML program design, transaction monitoring, KYC frameworks, sanctions screening, and regulator engagement. Senior-led counsel from attorneys and former in-house compliance operators.
UNITED STATES
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EUROPEAN UNION
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UNITED KINGDOM
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HONG KONG
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SINGAPORE
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UNITED STATES - EUROPEAN UNION - UNITED KINGDOM - HONG KONG - SINGAPORE -
THE COMPLIANCE PROBLEM AETHEMIS SOLVES
Crypto AML compliance is now a strategic imperative, not a procedural one.
The regulatory space is evolving faster than ever — the result is that AML and sanctions compliance has moved from a back-office function to a board-level concern. The cost of getting it wrong now routinely exceeds the cost of getting it right by an order of magnitude.
Most crypto businesses encounter this reality in one of three moments: when scaling forces a program rebuild, when an examination exposes gaps that vendor tooling cannot fix, or when an enforcement matter forces the question of whether the program was actually defensible.
Aethemis advises crypto businesses through these moments. We are not a vendor selling software. We are senior counsel and former in-house operators who design, build, and defend the compliance programs themselves.
WHAT WE DO
How we work with crypto businesses
Engagements typically fall into one of five service areas. Most clients work with us across several.
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AML program design and build-out
We design and implement BSA-compliant AML programs from the ground up, or rebuild programs that no longer fit the firm's scale, jurisdictional footprint, or risk profile.
The programs we build are designed to hold up under examination because they are built by people who have sat through examinations.
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Transaction monitoring advisory and tuning
We advise on transaction monitoring system selection, rule design, alert tuning, and false-positive reduction. We work with the major vendor platforms and we know which tools fit which business profiles.
We help compliance teams design transaction monitoring that catches what regulators expect to be caught, without burying the team in noise.
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KYC, CDD, and EDD framework design
We design risk-based customer due diligence frameworks that pass examination scrutiny and operate at scale.
This includes onboarding standards, ongoing monitoring, enhanced due diligence triggers, and PEP and adverse media screening.
We design the frameworks; vendors implement them. The difference matters when a regulator asks why a particular onboarding decision was made.
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Sanctions and OFAC compliance
We design and implement OFAC sanctions screening, wallet screening, and ongoing monitoring infrastructure aligned with current enforcement priorities.
This includes SDN screening, geographic restriction logic, and on-chain risk monitoring through integration with blockchain analytics platforms.
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Regulator engagement, examinations, and SAR strategy
We support clients through supervisory engagement, information requests, and SAR program design.
Our team includes former federal investigators and enforcement attorneys who have managed these relationships from inside government as well as inside in-house counsel functions.
When something goes wrong, we are the team that has handled it before from both sides of the table.
WHO WE WORK WITH
Who we advise
Our crypto AML work serves Chief Compliance Officers, Heads of Financial Crime, and in-house counsel at:
Crypto exchanges & trading platforms
Spot, derivatives, and OTC. Program design, transaction monitoring, examination response, and enforcement defense.
Custodians and wallet providers
AML and sanctions frameworks for custody operations, including wallet screening and on-chain monitoring.
Token & stablecoin issuers
GENIUS Act compliance, reserve attestation oversight, and AML program design for issuance and redemption activity.
Payment processors and fintechs
Crypto-fiat payment AML, MSB program design, and Travel Rule infrastructure.
WHY AETHEMIS
Why crypto compliance teams choose Aethemis
We have built these programs from the inside.
Our team includes former in-house compliance leaders. The programs we design are designed by people who have run them.
We are advisors, not vendors.
Our team integrates former in-house counsel from leading digital asset firms with former federal agents and enforcement attorneys. Clients get one team across law, strategy, and enforcement reality.
We integrate legal, operational, and enforcement perspectives.
Attorneys, former federal agents, and former in-house compliance operators on one team. Clients get one view across law, operations, and enforcement reality.
Practical, fast, and commercially aware.
REGULATORY COVERAGE
Regulatory frameworks and jurisdictions we advise on
Aethemis advises on AML and financial crime compliance across the frameworks that matter most to digital asset businesses operating at scale.
United States
Bank Secrecy Act (BSA)
FinCEN program requirements
GENIUS Act AML obligations
OFAC sanctions
State money transmitter AML standards
SAR filing strategy
Asia Pacific
Hong Kong SFC AML standards
Singapore MAS AML requirements
APAC cross-border AML coordination
European Union
MiCA AML obligations
6AMLD and AMLR compliance
National FIU engagement
CASP program standards
United Kingdom
FCA Money Laundering Regulations
Joint Money Laundering Steering Group (JMLSG) guidance
UK financial crime regime
Global
FATF Recommendation 15
Travel Rule implementation
FATF-aligned risk-based approach
Cross-jurisdictional counterparty due diligence
ENGAGEMENT MODELS
How engagements work
We work with crypto businesses on three engagement structures, depending on the situation.
Project-based engagements for defined scopes of work, such as an AML program build-out, a transaction monitoring rebuild, or an examination readiness review.
Retainer advisory for compliance teams that need ongoing senior counsel on AML, sanctions, and regulator questions as they arise, without rebuilding context each time.
Specialist matter support for time-sensitive issues such as examination response, enforcement matters, or SAR strategy in active investigations, where the team needs to mobilize quickly.
Engagements begin with a consultation to scope the matter, identify the right team members, and define the structure that fits.
FAQS
Frequently asked questions about crypto AML compliance
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Generally, a BSA-compliant crypto AML program includes a written program approved by the board, a designated compliance officer, ongoing training, independent testing, customer due diligence procedures, transaction monitoring, suspicious activity reporting, sanctions screening, and recordkeeping. The substantive content of each component depends on the business's risk profile, jurisdictional footprint, and the regulatory expectations of its primary supervisor.
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The compliance framework is broadly similar — risk-based approach, CDD, transaction monitoring, SAR filing — but the typologies and the operational realities differ significantly. Crypto AML requires on-chain analysis, wallet screening, counterparty VASP due diligence under the Travel Rule, and infrastructure that operates at the speed of blockchain settlement. The vendor ecosystem is also different, and the regulator expectations are evolving more quickly than in traditional banking.
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Yes. Vendor platforms execute the program; they do not constitute the program. Regulators expect a designated AML officer with the authority, training, and reporting structure to oversee the program independently. A compliance officer relying solely on vendor outputs without understanding the underlying rules and decisions is a common gap that examinations expose.
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Transaction monitoring tuning is the process of calibrating the rules and thresholds that determine which transactions generate alerts. Poorly tuned systems either bury the team in false positives (causing real risk to be missed) or set thresholds so high that genuinely suspicious activity goes undetected. Regulators look at tuning methodology in examinations, and inadequate tuning is one of the most common findings in BSA examinations of crypto firms.
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Yes. A significant portion of our AML work involves clients who are already mid-examination, in remediation under a consent order, or responding to a specific enforcement matter. We can step in at any stage.
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Cost depends on the scope, jurisdictions, and engagement structure. We are a senior-led firm and we are usually the right choice for businesses where the compliance question carries strategic or financial weight and the cost of getting it wrong is significantly higher than the cost of getting it right.
Speak with a crypto AML advisor
Whether you are building a program, tuning a transaction monitoring system, preparing for examination, or responding to enforcement, we should talk.