PLATFORM ARCHITECTURE AND INTEGRITY

Compliance Platforms Infrastructure Regulatory

ALA designs and implements platform integrity, trust architecture, and regulatory-grade governance frameworks for fintech, digital asset, blockchain, and other regulated technology companies.

We strengthen cybersecurity controls, internal controls, custody- and asset-protection structures, risk-management systems, and operational-resilience programs to withstand regulatory scrutiny, audits, enforcement review, and operational stress.

Drawing on experienced legal, compliance, cybersecurity, and financial services professionals, we build defensible security, governance, and compliance infrastructure that protects enterprise value and institutional trust.

REGULATORY AND RISK STRATEGY

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

  • AML program design

    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.

  • Transaction monitoring

    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.

  • KYC, CDD, and EDD framework

    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.

  • Sanctions and OFAC compliance

    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.

  • Regulator engagement, examinations, and SAR strategy

    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.

AML COMPLIANCE IS NOW A STRATEGIC IMPERATIVE

Blockchain regulation is fragmented. We make it operational.

Aethemis advises virtual asset service providers on licensing, AML and sanctions programs, regulator engagement, and cross-border compliance. Senior-led counsel from former in-house operators and federal regulators.

Crypto exchanges & trading platforms

Spot, derivatives, and OTC. Licensing, AML, market integrity, and cross-border structure.

Custodians and wallet providers

Custody licensing, segregation requirements, and operational risk frameworks.

Token issuers and stablecoin operators

Issuance structuring, ongoing CASP and VASP obligations, and reserve frameworks

Payment processors and fintechs

Digital asset payment licensing, MSB registration, and Travel Rule compliance.

  • Licensing strategy

    Licensing strategy and applications

    We scope the licensing path for your business, identify the most efficient sequence across jurisdictions, build the application materials, and manage regulator engagement through to authorization.

    Our team has worked across BitLicense, U.S. state money transmitter licensing, MiCA CASP authorization, FCA registration, SFC VASP licensing, and MAS payment services licensing. We understand what each regulator actually wants to see, which application questions are technical and which are political, and how to position a business for the smoothest path through.

  • AML Program Design

    AML, sanctions, and Travel Rule program design

    We design and implement AML, sanctions, and Travel Rule programs that meet BSA, MiCA, and FATF standards, and that work operationally inside a real business.

    Our compliance build-outs are led by attorneys and former in-house operators with direct experience designing transaction monitoring, customer due diligence, suspicious activity reporting, and Travel Rule infrastructure inside firms like Coinbase. The programs we build hold up under examination because they were built by people who have sat through them.

  • Cross-border regulatory strategy

    Cross-border regulatory strategy

    For VASPs operating in more than one jurisdiction, we coordinate licensing, structuring, and compliance obligations into a single coherent strategy.

    Multi-jurisdiction work is the default at Aethemis, not an upsell. We sequence applications efficiently, identify where passporting and reverse solicitation can be used to compress timelines, and make sure the structure in one market does not undermine the position in another.

  • Regulator engagement

    Regulator engagement, examinations, and enforcement

    We support clients through supervisory engagement, examinations, information requests, and enforcement matters.

    Members of our team have managed these relationships from inside federal agencies, inside in-house counsel functions, and across the table as outside advisors. That perspective changes how we prepare clients for regulator interaction and how we respond when something goes wrong.

The regulatory landscape for virtual asset service providers is no longer emerging. It is here, it is fragmented, and it is unforgiving.

Crypto exchanges, custodians, token issuers, and payment providers operating across jurisdictions face overlapping obligations under FATF, FinCEN, NYDFS, MiCA, FCA, SFC, MAS, and the Travel Rule, often simultaneously.

Most firms encounter this complexity in one of three moments: when applying for a license, when responding to a regulator, or when a deal, a launch, or a market entry forces the question. By that point the answers need to be fast, accurate, and commercially aware.

Aethemis advises VASPs through these moments. We work with crypto businesses to scope licensing requirements, design and build compliance programs, engage regulators, and coordinate strategy across the U.S., EU, UK, and APAC.

THE REGULATORY LANDSCAPE WE COVER

United States

  • FinCEN MSB registration

  • BSA AML program design

  • OFAC sanctions

  • NYDFS BitLicense

  • U.S. state money transmitter licensing

  • SEC and CFTC regulatory positioning

Asia Pacific

  • Hong Kong SFC VASP licensing

  • Singapore MAS payment services licensing

  • Cross-border APAC structuring

European Union

  • MiCA CASP authorization

  • MiCA passporting and third-country provisions

  • AMLD and AMLR compliance

  • National competent authority engagement

United Kingdom

  • FCA crypto-asset registration

  • Money Laundering Regulations

  • UK financial promotions regime

  • Proposed UK regulatory framework readiness

Global

  • FATF Recommendation 15

  • Travel Rule implementation

  • Cross-jurisdictional counterparty due diligence

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.

MONITORSHIPS & STRATEGIC REMEDIATION

Aethemis supports government monitorships and regulatory enforcement matter in technical, regulated environments

Our work focuses on translating enforcement mandates and consent orders into practical, defensible remediation that withstands regulatory scrutiny.

WHY 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.