AML Program Governance, Controls & Operating Models

Building & Running Effective AML Programs in Digital Asset Firms

An effective AML compliance program for a crypto firm requires much more than technology - it demands institutional governance, written policies, trained staff, independent testing, and a risk-based approach tailored to the firm's specific products and customer base. This whitepaper sets out the core components of a well-run AML program for digital asset businesses: appointment of a Chief Compliance Officer or BSA Officer; enterprise-wide risk assessments; documented AML/CFT policies and procedures; customer due diligence and EDD protocols; suspicious activity reporting workflows; independent audit cycles; and ongoing staff training. It examines how the Binance $4.3 billion settlement and Coinbase $100 million fine redefined compliance expectations for the industry, and how firms are investing in compliance infrastructure as a competitive differentiator. The whitepaper also addresses the near-total absence of formal AML governance in DeFi protocols and the growing compliance obligations of wallets, fintechs, stablecoin issuers, and other blockchain-native businesses.