Stout was engaged to assist a digital asset firm by establishing an anti-money laundering (AML) and sanctions program and implementing the program for the company, including their European operations.

We assisted in two phases:

  • AML and sanctions program development
  • AML and sanctions implementation support

AML and Sanctions Program Development

We developed the following components for the digital asset firm:

  • AML and Sanctions Policies and Procedures
  • A Training Program
  • An Independent Testing Program
  • Due Diligence
    •  Customer due diligence
    • Enhanced due diligence
  • Risk Management and Governance
    •  A model risk management framework
    • Customer risk rating
    • An asset (token) risk assessment methodology
    • Governance structures
    • Compliance risk reporting
  • Monitoring, Screening, Reporting
    • Transaction monitoring
    • Suspicious activity identification and reporting
    • Sanctions screening and reporting

Additionally, we performed an AML and sanctions risk assessment to document the company’s risk profiles, inherent risks, internal controls, and residual risks and identify any needed improvements.

AML and Sanctions Implementation Support

We assisted in the implementation of the AML and OFAC-related policies, procedures, and controls. This included:

  • Onboarding Procedures
    •  Performing customer onboarding procedures
    • Customer risk rating
  • Transaction Monitoring Procedures
    •  Performing alert review
    • Reviewing suspicious activity investigative procedures
  • Screening Procedures
    • Applying Know Your Customer (KYC) procedures
    • Applying Know Your Transaction (KYT) procedures
    • Conducting sanctions screening
    • Conducting adverse media screening
    • Conducting wallet screening

Outcome

Our services enabled the firm to develop and implement an effective AML and sanctions program in line with regulatory requirements of different jurisdictions.