Regulatory Area
AML Compliance
Anti-Money Laundering (AML) refers to the legal, regulatory and operational measures that businesses implement to prevent their products and services from being used for money laundering, terrorist financing and other forms of illicit finance.
In this briefing
- What it is
- Key things to know
Crypto businesses are now part of the global AML framework. Depending on the jurisdiction, exchanges, custodians, brokers, payment providers, stablecoin issuers and other crypto-asset service providers are required to implement AML/CFT programmes comparable to those expected of traditional financial institutions.
While the core principles remain the same, crypto introduces new risks, technologies and operating models. Firms must understand blockchain transactions, wallet structures, self-hosted wallets, on-chain analytics, Travel Rule requirements and cross-border regulatory expectations alongside traditional AML obligations.
Key things to know
AML is becoming increasingly global, but local differences still matter
AML frameworks around the world are increasingly aligned with the FATF Recommendations, particularly across customer due diligence, beneficial ownership, sanctions, transaction monitoring and the Travel Rule. However, local implementation still differs in areas such as accepted identity documents, verification standards, reporting obligations and regulatory expectations. Global businesses need a framework that can adapt to jurisdiction-specific requirements.
Every effective AML programme starts with the Business-Wide Risk Assessment
A Business-Wide Risk Assessment (BWRA) is the foundation of an effective AML framework. It enables firms to understand the financial crime risks created by their products, customers, jurisdictions, delivery channels and technology, allowing policies, procedures and controls to be designed proportionately to the risks the business actually faces.
Crypto AML requires crypto-native controls
Traditional AML controls alone are not sufficient for digital asset businesses. Effective programmes need to address crypto-specific risks and typologies through blockchain analytics, wallet screening, Travel Rule compliance, sanctions monitoring, blockchain investigations and controls tailored to digital asset products and infrastructure.
Transaction monitoring extends beyond fiat payments
Effective monitoring combines customer due diligence with blockchain intelligence, behavioural analytics, sanctions screening, wallet risk indicators, transaction monitoring and ongoing customer risk assessments. The objective is to understand both who the customer is and how they use crypto-assets throughout the customer lifecycle.
Technology supports decisions — it does not make them
Blockchain analytics, AI, transaction monitoring and screening solutions can significantly improve detection capabilities, but they do not replace governance or professional judgement. Firms remain responsible for investigations, escalation decisions, SAR/STR reporting and demonstrating to regulators how risks have been identified and managed.
Modern AML is about orchestration, not more tools
Financial crime teams increasingly operate across multiple data sources, blockchain analytics platforms, screening providers, identity solutions and internal systems. The challenge is no longer obtaining more data—it is connecting that data into a single, contextualised view that enables compliance teams to make faster, more informed and better-evidenced decisions. Modern AML programmes therefore rely as much on orchestration and workflow design as they do on individual compliance tools.
For general information only. Not legal, regulatory or compliance advice.
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